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Dry Cleaners Environmental Certification Workbook

For use with MassDEP’s Environmental Results Program

Revised 2015

Important Notice This workbook is a public domain document, and it is not copyrighted. The material may be reproduced for educational purposes but may not be sold for profit.

If you have questions regarding this workbook or other Dry Cleaner ERP related questions, please contact: [email protected] or call the ERP Help Line at 617-556-1097.

mailto:[email protected]

CONTENTS

Introduction ................................................................................................................................................................1

A. Facility Information ................................................................................................................................................3

B. Change in Status Guidance .....................................................................................................................................5

C. Compliance and Pollution Prevention Guidance ....................................................................................................6

Air Quality (Sections C1 through C16) ....................................................................................................................6

Air Quality Best Management Practices .......................................................................................................... 15

Industrial Wastewater (Sections C17 through C24)............................................................................................. 17

Industrial Wastewater Best Management Practices ........................................................................................ 20

Hazardous Waste (Sections C25 through C39) .................................................................................................... 22

Hazardous Waste Best Management Practices ............................................................................................... 29

D. Comments .......................................................................................................................................................... 30

E. Non-Perc Machine Information ........................................................................................................................... 30

F. Perc Alternative Information ............................................................................................................................... 30

Appendix A: Best Management Practices for Separator Water Disposal from Perc Dry Cleaning Machines ......... 31

Appendix B: Innovative Technologies For Dry Cleaners .......................................................................................... 32

Appendix C: Comparative Analysis .......................................................................................................................... 49

Appendix D: Pollution Prevention, Health & Safety Best Management Practices ................................................. 59

Appendix E: Spot Removers .................................................................................................................................... 62

Appendix F: MassDEP Inspector Checklist………………………………………………………………………………………………………….63

THIS PAGE INTENTIONALLY LEFT BLANK

Dry Cleaners Environmental Certification Workbook 1

INTRODUCTION

WHAT IS THE ENVIRONMENTAL RESULTS PROGRAM?

We at the Massachusetts Department of Environmental Protection (MassDEP) have fundamentally redesigned

environmental regulation to be less costly and more effective. We have replaced the 25 year-old system of

prescriptive case-by-case permits with comprehensive compliance certifications, industry wide performance

standards and streamlined regulation.

This new, common sense approach to regulation is the Massachusetts Environmental Results Program (ERP), a

regulatory system that we believe holds great promise for making it easier to meet — and exceed —

Massachusetts’ environmental standards. This new approach gives you the flexibility and information you need

to do the job, while improving accountability to the public for environmental performance.

ERP streamlines existing pollution control requirements for your dry cleaning company by combining

duplicative, and at times conflicting, federal and state requirements into one unified document. ERP is a

performance-based regulatory program designed to focus on results and outputs. This workbook provides you

with the information you need to understand and meet your environmental obligations.

You are required by MassDEP to comply with environmental regulations that apply to you, standards within this

workbook and the information contained within ERP Certification Forms. By answering the questions in the ERP

Certification form you certify that you comply with the requirements of 310 CMR 7.26(10) – (16) and 310 CMR

70.03 (Air Quality), 310 CMR 72.00 (Industrial Wastewater Standards for Dry Cleaners), and 310 CMR 30.0000

(Hazardous Waste). Regulatory citations are displayed for your information in [“brackets”].

You are required to submit a Certification Form to MassDEP when requested to do so by MassDEP. Annual

submittal of the ERP Certification form is required under 310 CMR 70.00 (Environmental Results Program

Certification) and 310 CMR 72.05 (Industrial Wastewater Standards for Dry Cleaners). Failure to comply with

these standards (submit the forms or submit the ERP fee) will require correction and possible enforcement

action by MassDEP.

Please read each standard and the information carefully and ask questions!

MassDEP is here to assist you in understanding and complying with environmental protection rules.

2 Dry Cleaners Environmental Certification Workbook

WHY IS MASSDEP INTERESTED IN DRY CLEANING?

Professional dry cleaners are an essential part of our communities; your services save us time and keep our

clothing in the best possible condition. Most dry cleaners are family-owned businesses, which have been good

neighbors for decades. Dry cleaning has become such a routine part of our lives that we rarely think about it.

But growing evidence that the primary chemical used to dry clean clothes, perchloroethylene (perc), can cause

damage to our health and the environment is making people think more about dry cleaning. For example,

although most dry cleaners recycle and reuse perchloroethylene within the dry cleaning system, it is possible to

lose significant amounts of perchloroethylene from each facility each year. Perchloroethylene is released into

the dry cleaning stores, and may be released into the homes of your customers, into your own homes and into

the air we breathe.

Perc and other cleaning chemicals, if improperly stored and managed, can also be released into the soil and

groundwater. Half the people in this country use groundwater (public and private wells) for drinking and many

dry cleaners use chemicals that could pollute groundwater if improperly handled. The continuing awareness of

environmental risks and the need for protecting public health has resulted in the enactment of more and more

laws. The United States Congress has decided that perchloroethylene is one of the toxic air pollutants that must

be regulated under the Clean Air Act. This federal law and its regulations are implemented by the United States

Environmental Protection Agency (EPA) and state environmental agencies. MassDEP is responsible for

implementing air quality protection laws, water protection and waste management laws. This is why MassDEP is

interested in improving the ability of dry cleaners to comply with environmental rules.

Perc has both acute and chronic adverse health effects. Acute effects can include skin, eye and respiratory

irritation, depression of central nervous system function, headache, dizziness, nausea, incoordination,

unconsciousness, and for very high exposures, death. The International Agency for Research on Cancer (IARC)

classifies perc in Group 2A (probably carcinogenic to humans) and the US National Toxicology Program classified

perc as "reasonably anticipated to be a human carcinogen; other chronic effects may include liver, kidney or

central nervous system damage. The developing fetus and children may be particularly vulnerable to the toxic

effects of perc.


A. FACILITY INFORMATION

This section provides guidance to those questions found in Section A of the ERP certification form.

Corresponding questions from the ERP form are noted in red.

FTE guidance and sample calculation (A1m)

Number of Full-Time Employee Equivalents (FTEs):

On the first page of the certification form under Section A (Facility Information), you will find item

1.m. The following description and example below will help you to provide the answer:

What is a full-time employee equivalent (FTE)? An FTE is defined as 2,000 hours worked. The total

number of FTEs at your facility depends only on the total number of hours worked by all employees

and not the number of persons working. The total number of hours worked should include all paid

vacation, paid holiday, and sick leave hours used by each employee. An FTE calculation should

include the time spent by all employees doing work related to the facility location where perc is

used; it should not include the time spent by employees relating to work at other separate locations

(e.g., store fronts at other locations).

To calculate the total number of FTEs at your facility, add up all of the hours worked by all your

employees, including your (the owner’s) time, and divide by 2,000. For example:

Owner: (50 hrs/week) X (52 weeks/year) = 2,600 hrs/year

Part-time help: (15 hrs/week) X (52 weeks/year) X (4 part time employees) = 3,120 hrs/year

Bookkeeper: (2 hrs/week) X (52 weeks/year) = 104 hrs/year

Presser: (24hrs/week) X (52 weeks/year) X (2 pressers) = 2,496 hrs/year

Tailor/seamstress: (12 hrs/week) X (52 weeks/year) = 624 hrs/year

Delivery truck driver: (20 hrs/week) X (52 weeks/year) = 1,040 hrs/year

Total hours = 9,984 hrs/year

Total full-time employee equivalents = 9,984 hrs/year divided by 2,000 hrs/FTE = 4.992 or 5 FTEs


Definitions and supporting information on co-residential and co-located facilities (A5 and A6)

Co-Residential Facility – If your dry cleaning business is located in a building with an apartment or

other residential space, even if vacant when you submit your certification, then your business is

considered to be co-residential, as defined by the USEPA.

Co-Located Facility - If your dry cleaning business is located in a building without a residence, but

with one or more of the following, then your business is considered to be co-located, as defined by

the MassDEP: [310 CMR 7.26(11)]

• Children’s pre-school • Health care facility • Licensed day care center • Prison • School (elementary, middle, or high) • Youth or senior center

Impacts if your dry cleaning business is co-residential or co-located:

Co-residential –

• Installation of a perc machine is prohibited after September 5, 2008. [310 CMR 7.26(12)(a)5] • Operation of any perc machine is prohibited after December 21, 2020. [310 CMR 7.26(12)(a)6]

Please note: if your business is co-residential and you installed a perc machine between December

21, 2005 and July 13, 2006, you are subject to federal requirements. Information is available from

the US EPA at: http://www.epa.gov/region1/contact/index.html

Co-located –

Installation of a perc machine is prohibited after November 5, 2008. [310 CMR 7.26(12)(a)4]

Operation of any perc machine is prohibited after December 21, 2020. [310 CMR 7.26(12)(a)6]

http://www.epa.gov/region1/contact/index.html


B. CHANGE IN STATUS GUIDANCE

If you operate a perc machine, do NOT complete the Change in Status section.

If you cease using perc as the dry cleaning solvent in your store, you must notify MassDEP of the change within

60 days. [310 CMR 7.26(15)(c)]

Check B1 if you cease all dry cleaning in your store (become a drop-off store), and enter the date of the change.

Check B2 if you cease all perc dry cleaning and use only perc-alternative solvent(s) and/or professional wet

cleaning.

Enter the date of the change, the new cleaning method, the number of new systems, and an estimate of the

quantity of alternative solvent you plan to use annually.

Check B3 if you change your business to only coin-operated dry cleaning machines.

Please note: If you check B1 or B2 and you have operated as a small quantity generator (SQG) of hazardous

waste, you should review your generator status. Otherwise, once your ERP classification is closed your remaining

SQG classification will result in a $525 annual compliance fee. To avoid a greater annual compliance fee: you

can, if applicable, change your generator status to VSQG, or if checking B2a "hydrocarbon", you may change

your status to VSQG or SQG for waste oil. If you have any questions about your generator status, call Mike

Hurley at 617-292-5633.


C. COMPLIANCE AND POLLUTION PREVENTION GUIDANCE

This section provides guidance to those questions found in Section C of the ERP certification form.

Corresponding questions from the ERP form are noted in red.

Air Quality (Sections C1 through C16) [Regulations at: 310 CMR 7.26(10) – (16)]

Definitions/Key Concepts

Air contaminant is any substance or man-made physical phenomenon in the open air space and

includes dust, gas, mist, odor, smoke, vapor, heat, sound, or any combination of these.

Air Emission is any discharge or release of any air contaminant to the open air space. For dry

cleaners, air emission come from perchloroethylene, dry cleaning machines, boilers, spotting

solvents or other contaminants to open air.

Compliance Assistance & Forms

(C1) The dry cleaning machine information items (a) (machine manufacturer and model) and (b) (serial number) can be obtained from the machine nameplate or from the manufacturer’s literature. Items (c), (d), or (e) (installation date) should be available in your records. Item (g) (control devices) - Your machine(s) is most likely equipped with a refrigerated condenser (3rd generation machine) or both a refrigerated condenser and a carbon adsorber (4th or 5th generation machine). If you are not sure, call the manufacturer or the person who maintains your equipment.

(C2) All transfer machines were required by the ERP program to cease operation after July 27,

2008. [7.26(12)(b)]

(C3a) If you installed a dry-to-dry machine after December 21, 2005, it must be equipped with a

refrigerated condenser and a secondary carbon absorber (a 4th or 5th generation machine).

The secondary carbon absorber (sometimes called a vapor absorber) reduces the perc vapor in

the drum just before the end of the cool-down cycle. [7.26(12)(a)3]

(C7) All dry-to-dry machines installed before December 9, 1991 must have either a carbon

absorber that was installed before September 22, 1993 or a refrigerated condenser. [7.26(12)(a)1]

(C8) If you have a refrigerated condenser installed on a dry-to-dry machine, you may not vent or

release perchloroethylene contained within the dry cleaning machine to the air. If air is pulled

through the door when the door is opened after the cycle, then a diverter valve must be used.

Avoiding the release of perchloroethylene to the air minimizes the amount you must purchase

each year to replace that which escaped. [7.26(13)(c)3]

(C9) You are required to check the refrigerated condenser at least once per week to be sure it is operating properly. [7.26(13)(c)] and [7.26(14)(a)1 or 2] You have 2 options:


1. The best way is to check the refrigeration system high pressure and low pressure gauges. During the drying cycle, the high and low pressures should be in the range specified in the manufacturer’s operating instructions. If you can’t find the gauges, refer to the operating manual or ask the manufacturer’s representative. You should post the correct high and low pressure ranges near the gauges for convenience. 2. The second option is to monitor the temperature on the outlet side of the refrigerated condenser. It should be equal to or less than 45°F (7.2°C) at the end of the cycle. This is probably the method you have been using to check the refrigerated condenser on your system. Remember to record the date and result (acceptable temperature or high and low pressures) in your log. See Forms C-1 and C-2 for examples of forms you can use to keep weekly monitoring records. [7.26(15)(d)5]

FORM C-1

Example: Equipment Monitoring Log Form — Refrigerated Condenser

High and Low Pressure Option

Observe the refrigeration system high and low pressure gauges during the drying cycle on a weekly basis. The high and low pressures must be within the normal ranges specified in the manufacturer’s operating manual.

Note the normal range specified in the manual here:_______________________________________

Date Inspector’s Initials

Machine No.

High Pressure Low Pressure

Are Both Pressures within

Normal Range

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

If the high or low pressure was outside the normal range, attach a completed corrective action report.


FORM C-2

Example: Equipment Monitoring Log Form — Refrigerated Condenser

Temperature Option

Measure the temperature on the outlet side of refrigerated condenser on a weekly basis.

Date Inspector’s Initials

Machine No. Temperature Is Temp. <45oF/7.2oC?

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

Yes/No

If the temperature was greater than 45° F/7.2 °C attach a completed corrective action report.

(C10) If the temperature at the outlet of the refrigerated condenser does not fall to or below 45

F at the end of the cool-down cycle, before the machine door is opened, or if the high and low

pressures are not within normal ranges, the system needs to be fixed. [7.26(13)(e)]

(C11) You should fix problems within 24 hours, if possible. If parts need to be ordered, they

must be ordered within 2 days after finding the problem, and repairs completed within 5 days

after receiving the parts. If your refrigerated condenser and/or carbon adsorber have not had a

problem, check the not applicable box. Use the corrective action log form C- 4 to document the

repair. Identifying and addressing problems in a timely manner minimizes the amount of

perchloroethlyene that you have to purchase each year to replace emissions to the air.

(C12) Conduct the weekly leak checks with the machine operating. In addition to using the leak

detection device, you should use your senses (smell, sight, and touch) to detect leaks. Places to

check for leaks include: seals, gaskets, hose/pipe fittings and valves. The information below can

be used to assist you in performing your weekly leak checks, using the appropriate methods and

equipment. [7.26(13)(h) and (i)]


(C13) You should try to fix leak problems within 24 hours, if possible. If parts have to be

ordered, they must be ordered within 2 days after finding the problem, and repairs completed

within 5 days after receiving the parts. If your dry cleaning machine has not had a leak, check

the "not applicable" box. Prompt leak detection and repair saves you money by minimizing the

need to purchase virgin perchloroethylene [7.26(13)(j)]

How to Conduct a Leak Check Step 1 Get checklist (Form C-3 below) and leak detection equipment.

Note: The Department of Environmental Protection (MassDEP) requires each facility to use one of the following types of device to detect leaks at dry cleaning facilities. Leak detection equipment must be operated and calibrated in compliance with manufacturer’s specifications. 1) a halogenated-hydrocarbon detector 2) a portable gas analyzer 3) an alternative device approved by the Department

In addition, you must check for perceptible leaks, that is, you must use your senses (e.g. sight, smell or touch) to detect leaks. NOTE: continuous exposure to perc and other chemicals can cause de-sensitivity to odor; therefore it is recommended that you have someone not continuously exposed to the solvent in use assist you with the assessment.

Step 2 Go to machines and locate proper leak detection points.

Required: Proper leak detection points are hose & pipe connections, fittings, couplings, valves, door gaskets & sealings, pumps, solvent tanks & containers, water separators, muck cookers, stills, exhaust dampers, diverter valves, filter gaskets & sealings and cartridge filter housings.

Step 3 Record readings from the leak detection equipment and record readings on the form for that machine. See the Equipment Leak Check Inspection Log (Form C-3), below.

Note: A vapor leak is an emission of perchloroethylene vapor from unintended openings in the dry cleaning system. Leaks waste perchloroethylene and your money. It is important for you to fix leaks promptly. If you find a leak, you must complete steps 4 or 5 Step 4

Record the leak detection

Repair the leak within 24 hours.

Record the activity you used to repair the leak in your corrective action log Form C-4. Step 5

If it is necessary to order a new part, order the part within 48 hours of leak detection.

Fix leak within 5 days after receiving parts.

Record the activity you used to repair the leak. Step 6

Keep all records of leak checks and repairs.


FORM C-3

Example: Multiple Equipment Leak Check Inspection Log Form

Date __________ Inspector __________

Inspection done by: (monitoring instrument)

Inspect the following items for leaks. Circle Yes or No.

Signs of Leaking

Machine No. Machine No. Machine No.

Hose & Pipe Connections, Fittings, Couplings, Valves Yes/No Yes/No Yes/No

Door gaskets & Sealings Yes/No Yes/No Yes/No

Pumps Yes/No Yes/No Yes/No

Solvent Tanks & Containers Yes/No Yes/No Yes/No

Water Separators Yes/No Yes/No Yes/No

Muck Cookers Yes/No Yes/No Yes/No

Stills Yes/No Yes/No Yes/No

Exhaust Dampers Yes/No Yes/No Yes/No

Diverter Valves Yes/No Yes/No Yes/No

Filter Gaskets & Sealings Yes/No Yes/No Yes/No

Cartridge Filter Housings Yes/No Yes/No Yes/No

If Yes was answered to any of the above, attach a completed corrective action report.


Halogenated Leak Detector Options

Perc is a chlorine-based chemical, and so can be detected by instruments that detect halogenated hydrocarbons. Based on information provided by leak detector manufacturers and tests conducted by other states or groups, the following units are expected to meet EPA guidelines. This is not an endorsement. Please note that this is not an exhaustive list. Further research is recommended to find the best leak detector for your dry cleaning facility. The first seven detectors below are available for$200±. The Aeroqual detector is available for $800±.

Product Manufacturer Model Sensitivity

Inficon Inc Tek-Mate <25 ppm

Inficon Inc The Compass <25 ppm

Nova Systems Products BOLO Green 5 ppm

TIF Instruments TIF8800A 1 ppm

TIF TIFXP-1A <25 ppm

TIF TIFRX-1A <25 ppm

TIF TIFXL-1A <25 ppm

Aeroqual Aeroqual 200 1 ppm


FORM C-4

Example: Corrective Action Log

Date of initial inspection ______________ Machine No.______________ Inspector ______________ Describe Problem:

Are Parts Needed Yes No (Circle One) Date Ordered ______________ Date Received ______________ Date Installed ______________

Date problem corrected ______________

Explain:


(C14) You are required to maintain the following records in your files for three (3) years:

[7.26(13)(k)] and 7.26(15)(d)]

Copy of design specifications and operating manuals for dry cleaning systems

Perchloroethylene purchase receipts, purchase log, and yearly perchloroethylene

consumption

Weekly equipment monitoring records

Weekly leak check records

Repair logs

To assist you with maintaining all required air quality management records the forms C-1 through C-4 in this section of the workbook, are provided for your use. Make copies of the example forms and keep them together in a binder.

- Perc purchases - keep receipts/invoices and monthly log (Form C-5) - Weekly leak checks – (Form C-3) - Weekly emission control monitoring – (Form C-1 or C-2) - Repairs – keep receipts/invoices and repair log (Form C-4)

- Keep the dry cleaning system operating manual in the shop.

(C16) The following (Form C-5) is an explanation of how to track your perc purchases during the

previous 12-month period. Remember to keep all purchase records and receipts. [7.26(15)(d)1

and 2]


FORM C-5 Steps to Calculate the Amount of Perchloroethylene You Purchased in the Last 12 Months

1) Use the chart below. 2) Add all perchloroethylene purchases made in each of the prior 12 months based on receipts. 3) Enter the correct amount purchased next to the correct month. 4) For the month(s) that you did not purchase Perchloroethylene, the gallons purchased is zero. 5) Add up all the months for a total amount purchased in the last 12 months.

1. ____________________ (Month) ____________________ (Amount)

2. ____________________ (Month) ____________________ (Amount)

3. ____________________ (Month) ____________________ (Amount)

4. ____________________ (Month) ____________________ (Amount)

5. ____________________ (Month) ____________________ (Amount)

6. ____________________ (Month) ____________________ (Amount)

7. ____________________ (Month) ____________________ (Amount)

8. ____________________ (Month) ____________________ (Amount)

9. ____________________ (Month) ____________________ (Amount)

10. ___________________ (Month) ____________________ (Amount)

11. ___________________ (Month) ____________________ (Amount)

12. ___________________ (Month) ____________________ (Amount)

TOTAL ____________________ (Amount)


Air Quality Best Management Practices

These best management practices are offered as ways that you can further improve the efficiency and

safety of your facility, beyond required compliance items above.

Operation & Maintenance

• Leaks should be repaired immediately and keep parts on hand. Leaks cost you money, expose

workers and contribute to air pollution.

• Regularly check air vents for drips.

• Replace faulty/worn gaskets on button trap and around cleaning machine door.

Drain all filter cartridges in their housings or in another sealed container for at least 24 hours

before properly handling them as a hazardous waste.

• Make sure additives you put in the solvent are dissolved before the solvent goes through the

filter.

• Be sure bulky items are completely dry before removing them from the dryer. Do not finish-dry

them outside the dryer.

Worker Protection

• Involve employees in pollution prevention and safety. All workers should understand and follow

rules and regulations.

• Avoid skin contact with perc. Perchloroethylene can cause skin irritation if it comes into contact

with skin repeatedly or for long periods of time.

• If splashed into the eyes, perchloroethylene can cause burning and irritation of the eyes. It is a

good idea to periodically monitor your employees’ exposure to perchloroethylene at work by

having them wear personal exposure badges.

• Perchloroethylene may cause reproductive effects and be absorbed in breast milk. Pregnant

women and nursing mothers should take precautions to minimize exposure to

perchloroethylene as much as possible.

• Perchloroethylene may be absorbed by certain foods such as dairy products, meat, fish, poultry,

fats, and oils. You should not store food or eat and drink in areas where perchloroethylene is

stored or used.

• Testing of air in dry cleaning shops has indicated that perchloroethylene levels can be quite high

especially for workers who operate or do maintenance work on dry cleaning machines. Dry

cleaning workers should wear respirators when they do maintenance work such as cleaning out

button traps, lint traps and stills and replacing filters. For complete information from the

Occupational Safety and Health Administration (OSHA), see their document titled "Reducing

Worker Exposure to Perchloroethylene (perc) in Dry Cleaning" here:

http://www.osha.gov/dsg/guidance/perc.html

• Minimize the opening of button traps and lint baskets.

• Minimize the time that the door of the dry cleaning machine is open.

http://www.osha.gov/dsg/guidance/perc.html


Materials Management

• Consider replacing hazardous pre-spotters with water-based, non-chlorinated pre-spotter.

• Use good record keeping practices to keep track of how much material is purchased, delivered

and sent off-site as waste.

• Supervise your deliveries to ensure everything you ordered is delivered and is in good condition.

• Recycle if possible by segregating: cardboard and cardboard boxes; plastic containers and plastic

film or wrap; metal and aluminum objects such as hangers; glass which is clean; or used

lubricating oil.

• Keep updated copies of Material Safety Data Sheets for all chemicals at the facility and update

yearly. This contains important health information.

General

• State governmental agencies such as economic development and small business assistance

organizations can help your business with understanding business regulations, financial

assistance and access to helpful business information.


Industrial Wastewater (Sections C17 through C24) [Regulations at: 310 CMR 72.00]


Industrial Wastewater is any wastewater resulting from any process of industry, manufacturing,

trade or business, regardless of volume or pollutant content. For dry cleaners, industrial

wastewaters include: separator water, vacuum water, washing machine water, compressor

water, non-contact cooling water, and boiler blowdown.

Discharge is the release of industrial wastewater to the waters of the Commonwealth from any

source through pipes, sewers, or other means.

All cleaners should include separator water in industrial wastewater discharged to the sewer,

container, holding tank, evaporator, or have a federal or state discharge permit. Dry cleaners

should be aware that local agencies may have additional discharge requirements that have to be

met. Discharges to surface water (e.g. streams, lakes, rivers) require a federal NPDES discharge

permit. Discharges to groundwater or ground require a MassDEP groundwater discharge permit.

Separator water may not be discharged to septic systems, cesspools, or leach fields.

Groundwater permits are often difficult to obtain and conditions of these permits are difficult to

maintain. You may choose to collect wastewater in a tank or container and dispose of it

accordingly instead of obtaining a permit.

Compliance Assistance & Forms

(C17) You are allowed to dispose of separator water by evaporation. Since separator water

contains a small amount of perc, it is best to vent the vapor from the evaporator to the outside,

and away from windows, doors or air intakes of adjacent buildings. You can minimize the

amount of perc being evaporated by passing the separator water through carbon filters before

evaporation. See the BMP Fact Sheet in Appendix A for the best way to manage separator

water. [310 CMR 72.04(6)]

(C18) This question refers to machines that use water and detergent/bleach for cleaning - no

organic solvents.

(C19) If you do not know if your facility is connected to a sewer, you can ask your landlord, local Department of Public Works (DPW), or Board of Health.

(C19c) The discharge of hazardous substances to the local POTW can cause serious issues, and

is, therefore, prohibited. [72.04(3)(b)]

If perchloroethylene were discharged to the sewer, it could leach out to the ground

through leaks in the sewer pipes.

Flammable materials create fire and explosion hazards to the sewer workers.


Corrosive materials include materials which have a pH lower than 5.0 or greater than

10.0. Corrosive materials, such as acids, "eat up" the pipes and pumps in the sewer

system that will contribute to leakage into the ground.

Solids, such as lint, can cause blockage and damage to residential and commercial piping

and treatment systems.

Heated wastewater has a temperature equal or greater than 104°F/40°C.

(C20a) Discharge of industrial wastewater, including separator water and laundry water, to

surface water (river, lakes, storm drains) is not allowed without a federal NPDES permit issued

by the EPA. Please note that storm drains discharge directly to surface water such as river, lakes

and other water bodies. For information, call the EPA at (617) 918-1111 (Customer Service

Center). [72.04(1)]

(C21) If you do not know if your facility is connected to a septic system, you can ask your

landlord, local Department of Public Works (DPW), or Board of Health.

(C21a) Discharge of any industrial wastewater, including separator water and laundry water, to

a septic system, cesspool, or leach field is prohibited. [72.04(1)]

(C22) Discharge to groundwater or directly on the ground requires a groundwater discharge

permit issued by MassDEP. Information can be obtained on the MassDEP website at:

http://www.mass.gov/eea/agencies/massdep/water/approvals/wastewater-forms.html

[72.04(1)]

(C23) If you store separator water in container(s) and ship it off-site, it must be handled as

hazardous waste. See Hazardous Waste Requirements beginning at question C25.

(C24) If you store laundry wastewater in containers and haul it off-site you must comply with

the following items. (Note: If you store separator water in containers and have it hauled off-site,

it must be stored and shipped as Hazardous Waste.) [72.04(5)]

Keep records of wastewater analysis;

Keep disposal manifests or bills of lading on site, for a period of three years;

Use containers that are in good condition;

Make sure containers are placed on a surface that does not have any cracks;

Provide a spill containment system if containers are stored outdoors;

Restrict entry to the general public into the storage areas; and

Label all containers with the words "Industrial Wastewater" or "Non-Hazardous Waste".

If you store laundry wastewater in permanent tanks and haul it off-site you must comply with the following items. (Note: If you store separator water in permanent tanks and have it hauled off-site, it must be stored and shipped as Hazardous Waste.) [72.04(5)]

http://www.mass.gov/eea/agencies/massdep/water/approvals/wastewater-forms.html


Have a containment structure with 110% capacity of the total volume of all above

ground tanks.

Have a bell and light alarm in a conspicuous location if they are remotely/automatically

filled tanks. The alarm is activated when the level of wastewater reaches seventy-five

(75) percent capacity of the tank and the alarm signal is transmitted to a staffed

location. Manually filled tanks are provided with visual or sight glass type of level

measurement;

Locate tank(s) to provide year round access for emptying;

Have odor control as necessary;

Tanks are made of, or lined with, materials that will not react with, and otherwise be

compatible with the industrial wastewater to be stored;

Locate tank(s) in a secured storage area which is free of cracks and gaps that is

sufficiently impervious to contain leaks and spills; and,

Have a label on tank(s) indicating contents are non-hazardous.


Industrial Wastewater Best Management Practices



Operations & Maintenance

• Please be sure to check all pipes that lead outside your building. If the pipe(s) empty to a street

drain it may lead to a stream, river, pond, or the pipe(s) may just lead to the ground. These

situations typically require permitting.

• Consider waste management costs when buying new dry cleaning equipment. Sometimes, a

more technologically advanced machine will save in operating expenses.

• Improperly maintained equipment could lead to air releases of perchloroethylene that could

raise the perchloroethylene air levels around your dry-cleaning shop. Perchloroethylene could

also leak from improperly stored waste or chemical containers that could lead to a groundwater

contamination problem.

• Often dry cleaning supply companies can supply trays made of plastic or other materials that are

put beneath containers to catch leaks or spills.

• Weekly checks for leaks and prompt repairs will save you money and benefit the environment.

• Tightly seal all bungs and lids on chemical containers.

• If dry detergents cause clogging in your cleaning systems and industrial wastewater discharges,

you might consider the use of liquid soap. You should note, however, that liquid soap, being

heavier, takes more energy and costs more to transport.

• Some suppliers or vendors can provide you with proper labels and manifests.

• Select reputable chemical suppliers and authorized waste transporters only.

• Drain all cartridge filters in closed containers.

• Do not underload or overload machines. Underloading can cause less efficient solvent use and

loss of solvent. Overloading can cause loose belts and make drying difficult.

• Place saturated lint from lint baskets in sealed hazardous waste containers.

• Inspect waste storage containers for leaks.


• Change operating procedures to reduce accidental and material losses. These procedural

improvements will also improve productivity.

• Make sure chemical containers are placed on a surface that does not have any cracks.

• Use chemical containers that are in good condition.

• Label all chemical containers regardless of the size. Even label "spot" dispensers and other small

containers.

• Use non-drip dispensing, such as spigot pumps, and funnels when transferring wastes to storage

containers.


• Consider the cost of waste management before buying new chemicals, materials, or accepting

samples from vendors.

• Make sure chemical containers won’t leak or be damaged by contents such as solvents and

perchloroethylene.

Worker Protection

• Both the known and potential adverse health effects resulting from perchloroethylene exposure

are cause for concern. As a result, proper handling of perchloroethylene and steps to eliminate

environmental releases and to minimize human exposure are essential.

• Make sure outside contractors who may be spending time in dry cleaning establishments are

aware of emergency procedures.

• Read and understand information on Material Safety Data Sheets and use them to educate

workers who may come in contact with the material. It is important to determine how a

hazardous substance should be handled.

• To minimize exposure to perchloroethylene in the workplace, make sure that your dry cleaning

shop complies with MassDEP storage and use requirements and that it is adequately ventilated.

• Develop an Emergency or "Contingency" plan for your dry cleaning facility so that you prevent

accidents and respond efficiently.

• Post emergency numbers by telephones and exits.

• Train all workers on what to do in an emergency.

• Make sure wall space where emergency signs and posters are located is uncluttered. It may be

helpful to remove all other posters that are posted to the walls.

General

• Heated wastewater kills the "bugs" that treat the wastewaters in treatment plants allowing the

discharge of untreated wastes to the river. Make sure your discharge is cooled.

• Industry associations for dry cleaners can assist your business through information sharing,

technical support, understanding government, finding good suppliers and other valuable

services.

• Pollution can contaminate groundwater and render it undrinkable for years. There are cases of

public and private wells being closed because of perc contamination.

• Dry cleaners may want to combine the various checklists and logs into one or two forms with all

of the required information on them. Check with your supplier, industry association or other dry

cleaners for examples.


Hazardous Waste (Sections C25 through C39) [Regulations at: 310 CMR 30.0000]


Hazardous waste is a chemical waste intended to be discarded or needing to be reclaimed to be

useful again for its original purpose that is dangerous to life and the environment when not

handled properly. For dry cleaners, hazardous waste includes waste perchloroethylene, muck,

filters for perchloroethylene, saturated rags/wipes/lint, etc.

Compliance Assistance & Forms - See

http://www.mass.gov/eea/agencies/massdep/recycle/regulations/fact-sheets.html#5 for additional

information on hazardous waste requirements, based on your generator status.

(C25) Your identification (ID) number must be 12 characters. If your generator status is:

Very Small Quantity Generator (VSQG) your ID# is self-assigned and it is [MV + 10 digit telephone number].

Small Quantity Generator (SQG) your ID# is assigned by DEP. You may use a temporary

number until you receive your permanent number. The temporary ID number is [MP +

10 digit telephone number.

If you do not have a hazardous waste generator identification number, or if you have not

registered with MassDEP, registration forms are available on MassDEP’s website at:

http://www.mass.gov/eea/agencies/massdep/recycle/approvals/hazardous-waste-

forms.html#5

You must complete the form and submit it to the appropriate MassDEP regional office.

(C26) The following FormC-6 will help you determine your status as a Very Small Quantity

Hazardous Waste Generator (VSQG), a Small Quantity Hazardous Waste Generator (SQG), or a

Large Quantity Hazardous Waste Generator (LQG). Dry Cleaners will most likely be VSQGs or

SQGs. [30.061(1) and 30.353(5)].

http://www.mass.gov/eea/agencies/massdep/recycle/regulations/fact-sheets.html#5

http://www.mass.gov/eea/agencies/massdep/recycle/approvals/hazardous-waste-forms.html#5

http://www.mass.gov/eea/agencies/massdep/recycle/approvals/hazardous-waste-forms.html#5


FORM C-6 Are you a Very Small, Small, or Large Quantity Hazardous Waste Generator?

Step 1. From your Hazardous Waste manifest copies; confirm your status as a Hazardous Waste Generator by completing the following:

Facility Name____________________ Year________

Amount of Waste Perchloroethylene Shipped on a Hazardous Waste Manifest

Example: In the above example, there are 6 shipments, the largest shipment is 240 lbs, generated over the shortest period of time which was 2 months, so the maximum generation rate may be considered to be 120 lbs. per month of HW.

(continued)


Step 2. Use your largest shipment generated over the shortest period of time, and divide it by the time it took to generate that amount, as above. Example:

My largest shipment was 240 LBS, and It took 2 Month(s) to generate that amount of waste Generation Rate = Lbs. divided by month(s) = LBS/Month(s). My maximum generation amount as determined above is 120 per month. Step 3. Use the chart below to find out if you are a Large Quantity Generator (LQG), Small Quantity Generator (SQG) or a Very Small Quantity Generator (VSQG).

If Yes... If No...

Step 3a Is the amount you determined more than 2200 lbs. per month?

You are a Large Quantity Generator (LQG). Contact MassDEP and Consult 310 CMR 30. As an LQG you are required to store hazardous waste less than 90 days.

Go to the next question

Step 3b Is the amount you determined more than 220 lbs. per month but less than 2200 lbs. per month?

You are a Small Quantity Generator (SQG). As an SQG you are required to store less than 4,400 lbs of hazardous waste and always store it less than 180 days.

Answer next question

Step 3c Is the amount you determined less than 220 lbs. per month?

You are a Very Small Quantity Generator (VSQG). As a VSQG you are required to always store less than 2,200 lbs of hazardous waste at any one time.


(C27) The amount of perc waste can be found in your copies of the Hazardous Waste Manifest. You should record the amount in pounds. If the amount of hazardous waste on the manifest is shown in other units, you must convert using the following formulas: Gallons: (# of gallons) X (13.5 lbs/gal) = lbs of perc 15 gallon Drums: (# of drums) X (15 gals/drum) X (13.5 lbs/gal) = lbs of perc (C28) VSQGs – No limit on how long you can store hazardous waste before shipping. SQGs – You cannot store hazardous waste longer than 180 days without shipping. Once you begin accumulating waste in a drum, you must ship that drum’s waste within 180 days. [30.351(6)(7) and 30.353(3)(4)] (C29) If you are a VSQG, you must store less than 2,200 pounds of waste at a time.[30.353(3)(4)] (C-30) You must be shipping hazardous waste to a licensed hazardous waste treatment storage or disposal facility or to a permitted hazardous waste recycler. You must also be using a licensed hazardous waste transporter for this task. A listing of licensed transporters is available at: http://www.mass.gov/eea/docs/dep/recycle/hazardous/hwtran.pdf You must maintain your logs, shipping records, and hazardous waste manifests on-site for at least three years. [30.351(10)(d) & (e) and 30.353(8) & (12)] (C31) An area for storage of only hazardous wastes must be designated at the facility; it must be separated from other areas of operation and clearly marked by a visible line, floor tape or fence. You must also post a sign with the words "HAZARDOUS WASTE" in this area and the sign must have letters that are at least one inch high. See the example below. [30.351(8) and 30.353(6)]

CAUTION

HAZARDOUS

WASTE

STORAGE AREA

http://www.mass.gov/eea/docs/dep/recycle/hazardous/hwtran.pdf


(C33) Waste containers that are dented, leaking or very rusty are considered not in good

condition. They must be replaced. Different wastes must be segregated into separate

containers. Waste oil must not be mixed with other waste. [30.351(8)(a) and [30.353(6)(g)]

(C34 and C39) All hazardous waste containers must be labeled and marked with the words

HAZARDOUS WASTE, the name of the waste and type of hazard (e.g., toxic, flammable) and

unless you are a VSQG, the date you started storing. See example labels below. Same as (C33).

In most instances the type of waste is perchloroethylene and the hazard type is toxic.

Shipping Label

Accumulation Label


(C35) Containers must be stored on a surface that does not have any cracks and that will

contain leaks and spills. Generally, intact concrete will contain leaks or spills. [30.351(8)(b)] and

30.353(6)(h)]

Waste containers or tanks stored outdoors, must have a spill containment system. See example

of spill containment system below. Spill containment must hold either 10% of the maximum

volume that can be stored and/or 110% of the volume of the largest single container (whichever

is greater).

(C36) Spills or leaks of perchloroethylene must be reported to MassDEP if:

1. it is greater than 10 lbs of material (equivalent to 0.7 gallons of perc), and 2. it is released to the environment (for example – released outside the building, to the air, to the ground, or to a storm drain, or to unlined trenches or sumps). Notify MassDEP of the spill/leak verbally within 2 hours, and follow up with a written report within 60 days.


In the event of a spill or leak that may threaten personnel or the environment you must notify

the local fire department, police department and the appropriate MassDEP Regional Office

during normal working hours (8:45 AM to 5:00 PM) M-F and ask for the Emergency Response

Section at (617) 556-1133.

(C37 and C38) Emergency response preparedness.

Be prepared for emergencies by having procedures to notify all of the proper agencies

immediately.

MassDEP at 1-888-304-1133

State Police at 508-820-2121

National Response Center at 1-800-424-8802

If you are a Small Quantity Generator (SQG) or a Large Quantity Generator (LQG) be prepared

for emergencies by: [30.351(9)]

Having an alarm or other communication system to notify employees.

Having a telephone, two-way radio or other device which can summon emergency

response agencies.

Having portable fire extinguishers and spill control equipment.

Having adequate supply and water pressure, automatic sprinklers or other fire

suppression equipment.

Having a program to periodically test emergency equipment

Having a program to train employees for emergencies.

Having adequate aisle space and clearly marked exits.

Having a program to familiarize and obtain agreements from the local emergency

response agencies such as the police department, fire department, hospital, etc.

Having a designated emergency coordinator.

Having posted names and telephone numbers of emergency coordinators: location of

fire alarms and extinguishers; telephone numbers of the fire department; and

evacuation routes for that location by the telephone.

LQGs should consult 310 CMR 30.341(1) for additional standards.

In a fire emergency, you should either attempt to extinguish the fire or call the local fire

department.

Please note: If you are a SQG, you must inspect your storage area once per week for leaking

containers, and have enough aisle space to conduct inspections and keep a log of your

inspections.


Hazardous Waste Best Management Practices



Operations & Maintenance

Keep records on all environmental management or safety related activities.

Clean lint filters often to maintain equipment efficiency, extend equipment life and reduce

maintenance requirements in other parts of the dry cleaning system.

Worker Protection

Studies have shown that dry cleaners can carry perchloroethylene home on their hair, clothes

and breath. As a result, workers and their families can breathe air at home that has much higher

concentrations of perchloroethylene than the typical "background" perchloroethylene

concentration in the homes of non-dry cleaners.

Occasionally, move caution and emergency posters to different locations so they will be noticed

and read.

Make sure you have personal protective equipment for emergencies (such as: goggles, gloves,

masks, etc.) and all of your employees known when and how to use it.

Use decals describing the hazards of perc by placing them on dry cleaning machines and other

appropriate areas.

Make sure the fire department knows about your emergency and evacuation plans.


You may want to keep manifests and shipping records indefinitely so you can always prove that

you handled your waste properly.

Make sure all old chemicals that are no longer needed are disposed of properly.

Keep hazardous wastes separated from non-hazardous wastes to decrease risk of

contamination.

Use spill response preparation to engage facility staff in an accident prevention program to

prevent leaks and spills from occurring.


D. COMMENTS

Use the Comments section to provide any additional information that you think is important for MassDEP to

understand your certification.

E. NON-PERC MACHINE INFORMATION

Please note that E1 through E3 are mandatory. If you operate a perc machine and a non-perc machine and/or professional wet cleaning system you must answer E1 through E3. Please note: Do not include standard laundry machines used to clean shirts, bed sheets or other traditional laundered items. (E1) Check "Yes" if you operate one or more non-perc solvent machine(s) and/or professional wet cleaning systems. Enter the machine information in E2. Check "No" if you do not operate non-perc machines and skip to Section F. (E2) Use Table E2 to supply the required information on your non-perc dry cleaning and/or professional wet

cleaning machine(s). Items:

a. (machine manufacturer and model) can be obtained from machine nameplate or manufacturer’s

literature

b. (serial number) also from the machine nameplate or from the manufacturer’s literature

c. (type of solvent or process) select the solvent or process you use from the drop-down list

d. (other process description) if the solvent or process is not on the list, enter the solvent name here

e. (installation date) should be available in your records

f. (date removed) fill in the date the machine is removed

(E3) To the best of your ability, estimate the percentage of all materials cleaned in your store during the

previous 12 months that are cleaned with perc and with other solvents and/or professional wet cleaning. For

example:

In 2012, I cleaned: 70% with perc and 30% with wet cleaning OR In 2012, I cleaned: 20% with perc and 80% with hydrocarbon, etc.

F. PERC ALTERNATIVE INFORMATION

Please note that answers to F1 – F6 are voluntary. These questions are designed to help you understand the

alternatives to perc when you consider purchasing a new cleaning machine.

Additional information on perc alternatives can be found in Appendix B.


APPENDIX A: BEST MANAGEMENT PRACTICES FOR SEPARATOR WATER DISPOSAL FROM

PERC DRY CLEANING MACHINES

The purpose of this fact sheet is to provide you, the owner/operator, with guidance for managing and disposing

of separator water generated in the normal operation of your perc dry cleaning machines.

Separator water with a perc concentration of 0.7 parts per million (ppm) or more is considered to be hazardous

waste. Separator water accumulated in a properly operated perc/water separator contains perc at

concentrations up to 150 ppm, and therefore, is a hazardous waste.

To minimize the amount of perc in your separator water, you should maintain and operate the water separator

as recommended by the manufacturer, including keeping it clean and operated within the proper temperature

range. A well maintained water separator minimizes the exposure of your customers, staff and the environment

to a toxic chemical.

There are two basic options for disposal of separator water:

1. Store your separator water in drum(s)/container(s) with a tight fitting lid(s), label as Hazardous Waste, Separator Water, Toxic and with the date accumulation began in the container(s) and ship them to a licensed treatment, storage and disposal (TSD) facility (310 CMR 30.000).

2. Evaporate the separator water. Please Note: The Department’s Hazardous Waste regulations prohibit heating unfiltered (not passed through a carbon filter) separator water. (310 CMR 30.353(10))

Best management practices when evaporating separator water

The use of a "mister" is not recommended.

None of the perc recovered in the separator can be evaporated. A properly operated and maintained separator will eliminate this worry.

An evaporator equipped with carbon filters in series to reduce the perc concentration in the wastewater to below the level of hazardous waste prior to evaporation is recommended. > To minimize spills, vapor odors, and to simplify the process, the water separator should be hard-

piped to the evaporator, if feasible. Small quantity generators (SQG) are required to hard-pipe the separator to the evaporator.

> If the water separator is not hard-piped to the evaporator, the container used to collect separator water must be kept closed and labeled as "Perc Separator Water". You must be careful not to spill separator water when transferring it to the evaporator.

The evaporator should be vented to the outdoor air, not indoors. > The evaporator should be vented as high into the outside air as feasible. A well designed stack will

allow for effective dispersion of the vapors. > Do not vent the evaporator near a window or air intake of the facility or an adjacent building.

Spent carbon filters from the evaporator must be stored and shipped as hazardous waste (310 CMR 30.000).

Keep records of the maintenance, repairs and filter changes to the evaporator to show you are operating and maintaining the unit in accordance with the manufacturer’s requirements.


APPENDIX B: INNOVATIVE TECHNOLOGIES FOR DRY CLEANERS

As in many other industries, technology advances are being pursued in garment cleaning to make cleaning

processes faster, better and less expensive. Sound management practices would encourage dry cleaners to

stay abreast of new technology advances since they may offer opportunities for you to do garment cleaning in

new and effective ways, with reduced environmental impacts and improved health and safety for business

owners, employees and customers. Talk to your suppliers and vendors, your trade associations and

environmental agencies.

Traditional dry cleaning with perc has served the industry well for more than fifty years and technological

improvements continue to reduce the danger from perc exposure or contamination. Perc was introduced as a

non-flammable alternative to the highly flammable hydrocarbon solvents that were the industry standard at the

time. However, while perc cleans well and is non-flammable, the chemical may cause damage to your health

and the environment and in recent years there has been increasing pressure from a number of sources to

reduce the use of perc. Exposure to operators, customers and residents near perc dry cleaners is a growing

concern. Fortunately, the garment cleaning industry has a growing number of technologies to choose from for

reducing perc. Some of these technologies include new, more efficient perc dry cleaning machines, while other

technologies completely eliminate perc. For those interested in exploring alternatives to perc, a brief summary

of current commercial technologies is listed below. Appearance on this list does not indicate that the cleaning

method is safer than perc cleaning regardless of manufacturer claims. Each of these technologies, like traditional

dry cleaning, has strengths, weaknesses and limitations.

Further information on these and other technologies is available from your environmental agencies (including

MassDEP, OTA, and TURI), trade associations, vendors, and suppliers. In 2012 TURI conducted an assessment of

seven common alternatives to perc to find technically viable and environmentally preferred methods for

professional garment cleaning. The alternatives evaluated were: professional wet cleaning, liquid carbon

dioxide, high flash hydrocarbons, acetal, propylene glycol ethers, cyclic volatile methyl siloxane, and n-propyl

bromide. The full report and a four page summary can be found at www.turi.org/drycleaning under the resource

section.

This section is included in the workbook to provide cleaners with current and un-biased information about

alternatives to perc used in dry cleaning. For more detailed worksheets to use when conducting an analysis for

your facility, please refer to Appendix C for Comparative Analysis forms.

http://www.turi.org/drycleaning


APPENDIX B 1.0 DESCRIPTION OF ALTERNATIVES

PROFESSIONAL WET CLEANING

Professional wet cleaning is a water-based cleaning process, which uses computer-controlled washers and

dryers along with biodegradable detergents and specialized finishing equipment to process delicate garments

that would otherwise be dry cleaned. Detergents used in wet cleaning are typically supplied by a detergent (or

soap) supplier and injected into the washer through a computer-controlled and programmable pumping system.

There are currently at least twelve dedicated wet cleaning facilities in Massachusetts, and many others who

process some portion of their garments using wet cleaning.

LIQUID CARBON DIOXIDE

Carbon dioxide (CO2), as either a liquid or a supercritical fluid, can be used to clean garments in specialized

equipment. The most common process uses liquid carbon dioxide at a pressure of 700 pounds per square inch

and uses detergents specifically designed for this process. The CO2 method of garment cleaning combines liquid

carbon dioxide with cleaning agents in a traditional basket-style machine. Currently, this method is not in use in

Massachusetts, and is not a widely available option in the US. Equipment is currently available from Cool Clean

Technologies, Inc.

HIGH FLASH HYDROCARBONS

High flash hydrocarbons are a class of low-odor petroleum-based dry cleaning solvents characterized by a flash

point greater than 140oF (combustible liquids). This technology is the most widely used alternative to perc dry

cleaning. The most common high flash point hydrocarbon solvent in use in Massachusetts is DF-2000TM.

ACETAL

Acetals are halogen-free combustible solvents. A new acetal-based dry cleaning solvent system came onto the

US market in 2010, manufactured and distributed by Kreussler Inc. using the name Solvon K4. Solvon K4’s main

ingredient is 1-(butoxymethoxy) butane, also referred to as butylal or formaldehyde dibutyl acetal. Several

Massachusetts cleaners have switched or are considering switching from perc to Solvon K4.

PROPYLENE GLYCOL ETHERS

Glycol ethers are a class of petroleum solvents that were introduced as an alternative to perc in dry cleaning in

the late 1990s. Glycol ether systems can typically be used with a hydrocarbon machine after minor

modifications. Some commercially available products are also hybrid systems, combined with hydrocarbons or

liquid CO2. Several glycol ether systems have been commercially available, and several cleaners in

Massachusetts reportedly use these systems.


CYCLIC VOLATILE METHYL SILOXANE

The current volatile methyl siloxane used in dry cleaning is the cyclic VMS decamethylcyclopentasiloxane (D5).

Using D5 in dry cleaning is trademarked as the GreenEarth® dry cleaning system. It is an odorless, combustible

liquid used in multi-solvent machines. GreenEarth® Cleaning claims that most 4th and 5th generation machines

currently being used with hydrocarbons can be modified for use with D5. Many cleaners in Massachusetts use

D5, though an exact number is not known.

Other toxic chemicals used in dry cleaning:

N-PROPYL BROMIDE

N-Propyl bromide (nPB) is considered a "drop-in" replacement for perc in dry cleaning applications, which

indicates that it can be used in existing (generation 3 or higher) perc dry cleaning equipment. nPB could be used

in hydrocarbon equipment as well, although this would require more extensive modifications, including

corrosion resistance. Several cleaners in Massachusetts have switched or are considering switching their perc

systems to nPB.

n-Propyl Bromide (nPB) Warning: nPB is listed as a Toxic or Hazardous Substance under the Massachusetts

Toxics Use Reduction Act (TURA) and is not considered a safer alternative to perc. nPB is associated with cancer,

reproductive/developmental toxicity, and effects on the central nervous system.


APPENDIX B 2.0 ECONOMIC ANALYSIS OF ALTERNATIVES

Dry cleaners are typically small operations where capital equipment costs can dictate decision-making. The table

below provides a summary of costs associated with the seven alternatives as compared with perc.

Based on the available financial data presented in the table, the following highlights are apparent:

• Wet cleaning requires the least amount of energy of the other systems, both in electricity and in natural

gas usage. Studies conducted by the Massachusetts Toxics Use Reduction Institute (Onasch 2010)

indicate that significant energy reductions can be associated with the use of wet cleaning over perc-

based dry cleaning systems, when it is the sole system used at a facility, eliminating the use of solvent

recovery systems.

• The Acetal system shows promise of energy use reduction as it reportedly has a much lower energy

requirement for solvent distillation, requiring only half the BTUs of a perc system.

• Wet cleaning has comparable equipment and operational costs to perc, although detergent costs are

higher than perc, and more detergent is required for the process.

• The capital costs for the acetal system are somewhat higher than perc, but facilities may see payback on

their investment through lower steam heat costs. As this chemistry is new to the market, it is expected

that additional studies will reveal how the costs play out for facilities using the acetal chemistry.

• Costs for nPB are significantly higher than for perc based on the cost per gallon of the chemistries. In

addition, as noted in the regulatory section of this report, nPB use may result in additional

Massachusetts regulatory requirements if facilities exceed TURA reporting and planning thresholds.

• The carbon dioxide option is cost-prohibitive for many small shops due to the high upfront capital cost

of equipment. However, if installed, the chemical costs may be lower for a facility.

• In addition to the information presented in Table 4, cleaners may find it helpful to know that existing

higher generation (4th generation and higher) perc or hydrocarbon systems could be retrofitted for use

with nPB, siloxane or acetal.

DRY CLEANING ALTERNATIVES – FINANCIAL DATA (SEE SECTION IV, PAGE 32 OF PERC ALTERNATIVES ANALYSIS)

1 The cost per pound cleaned, based on case study facilities in California, includes capital, solvent, licensing, detergent, electricity, gas, spotting labor, finishing

and maintenance labor, maintenance of equipment, compliance, and hazardous waste disposal costs (IRTA 2005). For technologies with multiple case study facilities, both the range and average cost are shown. 2 Sinsheimer 2009

Assessment Criteria Perc Wet Cleaning Carbon Dioxide

High Flash

Hydro-

carbons

Acetal

Propylene Glycol Ethers

Siloxane n-Propyl

Bromide

Equipment costs (ranges relate to capacity, quality and features of machines)

$40,000 to

$65,000

$36,000 to

$61,000

$100,000 to

>$150,000

$38,000 to

$75,000

$50,000 to

$100,000 $56,000

$30,500 to

$55,000

$40,000 to $60,000

(or retrofit costs for

existing perc equipment)

Solvent costs (per gallon) $17

$.007/gal

(water use

fee) + $25-

$31/gal

(detergent)

$0.18/lb CO2 +

$40/gal

detergent

$14-$17 $28-$34 $25-$30 $22-$28 $40-$64

Total cost per pound cleaned

(range and average)1

$0.63 - $1.94

Avg: $1.02

$0.57 - $1.32

Avg: $1.10 $1.40

$0.73 -

$1.02

Avg: $0.88

Unavailable $1.14 $1.08 - $2.33

Avg: $1.71 Unavailable

Estimated electricity usage for equipment operation (kWh/100 lbs)

26.6 9.3 30.9 35.5

Assumed to be

similar to

hydrocarbon

Unavailable 54.2 Unavailable

Estimated natural gas usage for hot water and steam heat used for drying, distillation, and pressing

(therms/100 lbs)2

12 9 7.3-14.2 13.1

Natural gas use

for solvent

distillation more

energy efficient

than HC or perc

Unavailable 13.4 Unavailable

36

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APPENDIX B 3.0 TECHNICAL ANALYSIS OF ALTERNATIVES

Key technical parameters for dry cleaners include cycle time, load capacity, and quality of cleaning. Additional

considerations include pre-spotting and maintenance requirements, additional finishing or control equipment,

equipment availability and vendor support, solvent odor issues, and waste management. The table below

provides a summary of several technical performance assessment criteria important to dry cleaners. It should

be noted that individual cleaner’s experience with each of the systems varies, and depends on their mix of

garments and soils, as well as their choice of detergent and spotting chemistries.

Observations about the technical performance of the alternatives as summarized in the table include:

• Wet cleaning cycle times are typically shorter than other systems – using a separate washer and dryer

allows the two cycles to overlap, thereby saving time. Massachusetts cleaners that have converted to

dedicated wet cleaning claim that they have significantly reduced their time at the spotting board. This

is at least in part because most of the stains on clothes are well suited to removal by the water and

detergent chemistries and technology. Wet cleaning exhibits better cleaning results for most fabric

types, including the fact that clothes are less dingy than when cleaned with a recycled solvent.

Massachusetts cleaners have stated that "whites are whiter and brights are brighter."

• Hydrocarbon systems exhibit similar productivity to that of perc-based systems, and are said to produce

a cleaner garment overall than some of the other solvent-based systems.

• CO2 systems exhibit better productivity than perc-based systems, but may require more spotting for

sufficient cleaning.

• According to the manufacturer, the acetal system has a similar cycle time to perc, a wide range of load

capacities and is able to clean a wide range of fabrics with minimal pretreatment.

• Performance of nPB is expected to be similar to that of perc-based systems. It is reported that nPB

systems would have similar difficulty with certain fabrics, and excessive color "bleed," as perc-based

systems.

• Longer cycle times and smaller load capacities in propylene glycol ether and siloxane-based systems

make them less productive than perc-based systems.

• The spotting requirements for propylene glycol ether systems are reported to be less demanding than

for perc. Propylene glycol ether systems are compatible with a wider range of fabrics and garments than

perc-based systems.

• Siloxane systems are reported to require more pre-spotting than perc systems.

DRY CLEANING ALTERNATIVES - TECHNICAL DATA (SEE SECTION IV, PAGE 30 OF PERC ALTERNATIVES ANALYSIS)

Assessment Criteria

Perc Wet

Cleaning Carbon Dioxide

High Flash Hydrocarbons

Acetal Propylene

Glycol Ethers Siloxane

n-Propyl Bromide

Cycle time (min) 45 20-40 35-45 60-75 60-65 > 45 53-58 45

Load capacity (lbs)

50 20-75 60 35-90 40-90 43 55 50

Cleaning capability

Aggressive3

Less aggressive

Less aggressive

Less aggressive Unclassified Unclassified, but gentle on

fabrics Less aggressive Aggressive

Fiber/garment types that are difficult for this alternative

Leather, suede, beads,

delicates

Leather, suede and

fur

Triacetates, specially

dyed acetates

Vinyl appliqués

Appliqués or decorations

glued to fabric

None identified

None identified Leather, suedes, beads, delicates

Time required for pre-spotting

Medium Low High Medium Low Low High Low

Equipment compatibility

Perc equipment

Wet cleaning

equipment

CO2

equipment Hydrocarbon

Retrofit hydrocarbon or new acetal

system

Retrofit 4th

Gen or higher

hydrocarbon

Retrofit perc or hydrocarbon 4

th

Gen or higher

Retrofit perc or hydrocarbon 4

th

Gen or higher

Special equipment

Vapor recovery

equipment

Additional finishing

equipment and training

required

High pressure

equipment

Combustible – must meet fire safety codes

Combustible – must meet

fire safety codes

Combustible – must meet

fire safety codes

Combustible – must meet fire

safety codes

New seals, gaskets and

doors may be required

Waste management concerns

Handle spent

solvent and solids as

hazardous waste

Requires discharge to

sewer or holding tank

Waste soils and lint do not require

special handling

Considered as waste oil in MA, to be disposed of

as hazardous waste; empty containers may

contain residual solvent and may be dangerous

Waste solvent

disposed of as industrial

waste

Difficult to distill water

prior to waste mgmt

Separate solvent from water

before disposal; not required to be treated as

hazardous waste

If used as a drop in replacement,

residual perc may be present

for up to 6 months

3 The term "aggressive" refers to the ability of the solvent/system to thoroughly remove soils from any garment. This also encompasses the potential for

causing wear on garment fibers.

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APPENDIX B 4.0 ENVIRONMENTAL AND HUMAN HEALTH COMPARISON OF ALTERNATIVES

A primary concern for dry cleaners is worker and customer exposure to volatile organic emissions. In addition,

the historical experience of soil and groundwater contamination related to dry cleaning operations, and the

financial liability associated with remediation of these events, further underscores the importance of selecting

safer alternatives. Table 6 provides a summary of environmental and human health data associated with the

alternatives.

It is important to note that the environmental and human health data associated with the wet cleaning system is

based on the detergent and additive package that is largely responsible for the cleaning performance (as

opposed to the solvent, which for this technology is water). Similar detergents and performance booster

formulations are added to other solvent systems, including perc, but typically at lower concentrations. In wet

cleaning, the detergent/additive package typically constitutes 3% to 5% by volume of the overall solution in

which clothes are placed. In contrast, the detergent/additives that are used in other systems make up no more

than 1% by volume of the overall solution in which clothes are placed.

The following are highlights of the environmental and human health considerations of alternative solvents in

comparison to those of perc:

The environmental and human health data analyzed for the wet cleaning system demonstrates that it

poses the least potential risk to human health and the environment of the alternatives assessed.

The CO2 system generally exhibits better environmental and human health characteristics than perc

systems. CO2 systems have unique concerns associated with high pressure equipment and the potential

for leaks and associated exposure to high concentrations of CO2.

Modeled information for butylal (the acetal) indicates similar aquatic toxicity characteristics as those for

perc. Butylal is a volatile organic compound, indicating a potential for occupational exposure. Because

the acetal solvent Solvon K4 is a new product, very little test data is currently available. The majority of

human health effect data referenced here is based on product data provided by the manufacturer. The

gaps in data may lead to a different comparative conclusion relative to perc after more is learned about

the environmental and human health implications of acetals.

Propylene glycol ethers are not expected to be harmful to the environment with regard to persistence,

bioaccumulation or aquatic toxicity. Health effects of concern pertain to irritation and potential effects

on the liver, kidneys or CNS. In addition, studies suggest that metabolism of one minor element of the

overall composition might be linked with reproductive toxicity concerns.

High flash point hydrocarbons present a high concern for aquatic toxicity, should there be a release into

the aqueous environment. There are also concerns around bioaccumulation and effects on the central

nervous system.

D5 exhibits persistence, bioaccumulation potential, and aquatic toxicity characteristics that are of

concern. In particular, modeling data indicates that D5 is highly persistent in sediments and air, and has

high aquatic toxicity. Studies indicate that D5 may represent a reproductive hazard, and one recent

animal study shows evidence of carcinogenicity.


While nPB, a volatile organic compound, is less persistent in most media than is perc, it is highly

persistent in air and, because of its volatility, represents a potentially significant occupational exposure

risk. nPB is also highly toxic to aquatic species. nPB has been determined to be a reproductive and

developmental toxicant and exhibits central nervous system effects. Finally, recent studies by the

National Toxicology Program indicate clear evidence of carcinogenicity in certain animals.

TABLE 6A: DRY CLEANING ALTERNATIVES – ECOLOGICAL AND ENVIRONMENTAL INFORMATION

Assessment Criteria Perc Wet Cleaning4

Carbon Dioxide

High Flash

Hydrocarbons Acetal

Propylene Glycol Ethers

Siloxane n-Propyl Bromide

Representative CAS #(s) 127-18-4

106232-83-1, 26027-37-2,

69227-21-0, 112-34-5, 29923-31-7,

& 61791-32-05

124-38-9 68551-17-7,

64742-48-9 2568-90-3

29911-28-2,

132739-31-2 541-02-6 106-94-5

Persistence (water, soil, sediment and/or air)

6

M (water),

H (soil, sed, air)

L (water, soil, air),

M (sed)

NA L (water, soil, air),

M (sed)


M (sed)


M (sed)

L (water),

M (soil),

H (sed, air)

L (water, soil),

M (sed),

H (air)

Bioaccumulation7 Low Low NA Mod Low Low Mod Low

Aquatic toxicity (mg/L)8 Mod (5) Low to Mod

9 Low (35) High (0.023) Mod (2.9)

10 Low (84) High (0.021) High (0.051)

Volatile Organic Compound Yes, Exempt11

No12

No Yes Yes Yes Yes,

Exempt13

Yes

4 Important note: The primary solvent in wet cleaning is water. For the purposes of this table, the EH&S information provided applies to undiluted detergents and other additives common

in wet cleaning processes, which are also common in other cleaning systems. These additives are present in amounts of 3% to 5% in wet cleaning, and are used in lesser amounts in other systems (typically around 1%).

5 These represent the primary (i.e., present in additive formulations at or greater than 1% by volume) undiluted detergents and additives included in this assessment.

6 Persistence criteria in each of the environmental compartments: Air [L<=2 days, H>2 days]; Sediment, Soil & Water [L<60 days, M>=60 days, H>180 days]. Low (L) is considered to be ‘Not

Persistent.’ 7 Bioaccumulation criteria: Low (Not Bioaccumulative) <1,000, Mod (Bioaccumulative) >= 1,000.

8 Fish ChV (mg/l) Toxicity criteria: Low (Not Toxic) > 10mg/l or no effects at saturation, Mod (Toxic) <10 mg/l, High (Toxic) <0.1 mg/l.

9 This system is characterized as Low aquatic toxicity, with the exception of one constituent of the detergent package Lanadol Aktiv; it contains 1-5% of Oleic acid Monoethanolamid,

ethoxylated (CAS# 26027-37-2), which is predicted to be moderately toxic but readily biodegradable. 10

This value (based on the PBT Profiler model) differs from the Kreussler MSDS which states Solvon K4 is insoluble in water, and would therefore not reach a concentration in water

sufficient to cause aquatic toxicity. 11

Exempt from USEPA and MassDEP VOC regulations by rule, due to determination of negligible photochemical reactivity. 12

This assessment is for the overall system composition. One component of the cleaning package Lanadol Avant contains 1-5% of 2-(2-butoxyethoxy) ethanol (CAS# 112-34-5), which is a

VOC based on its boiling point of 439°F. 13

Exempt from USEPA and MassDEP VOC regulations due to determination of negligible photochemical reactivity; U.S. EPA, 1994, direct final rulemaking: D5 specifically exempt from

regulation as a Volatile Organic Compound (VOC).

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TABLE 6B: DRY CLEANING ALTERNATIVES – HEALTH EFFECTS

Assessment Criteria Perc Wet

Cleaning14

Carbon Dioxide

High Flash Hydrocarbons

Acetal15

Propylene

Glycol Ethers Siloxane n-Propyl Bromide

Carcinogenicity Probable Human Carcinogen (IARC

2A)

Not classified by IARC



Not classified by

IARC


Some evidence

Clear evidence in animal

studies by NTP

Reproductive or developmental toxicity

Yes Negligible16

No data available

No data available

No data available

No17

Studies indicate

concern Yes

LD50 Oral, rat,

2,629 mg/kg NA

18 NA

Oral, rat, >5,000 mg/kg

Oral, rat, 6,873 mg/kg

Oral, rat, >3700 mg/kg



Dermal/ocular/ respiratory irritant

All Dermal, ocular

Dermal, ocular

All Possibly

dermal, ocular All Dermal, ocular All

Central nervous system effects

Yes Negligible19

No20

Yes No data available

Yes Some evidence Yes

Other target organs Liver, kidneys, immune and

hematologic system Negligible

21

Heart, lungs

Lungs, kidneys None known Liver, kidneys Liver, immune

system

Liver, kidney, digestive &

blood systems

Recommended exposure limit

25 ppm22

NE 5000

ppm23

100 ppm

24 NE NE 10 ppm

25 10 ppm

26

NA = not applicable; NE = not established 14

Important note: The primary solvent in wet cleaning is water. For the purposes of this table, the EH&S information provided applies to undiluted detergents and other additives common in wet cleaning processes, which are also common in other cleaning systems. These additives are present in amounts of 3% to 5% in wet cleaning, and are used in lesser amounts in other systems (typically around 1%).

15 Except where noted, information on acetals is provided by the manufacturer, and has not been independently assessed.

16 Lanadol Avant contains 1-5% of 2-(2-butoxyethoxy) ethanol (CAS# 112-34-5), which can cause fertility impairment or teratogenesis (HAZMAP 2011). Concentration in washer

is approximately 0.1%, which is below accepted de minimis. 17

Possible reproductive effects from minor β-isomer of propylene glycol ethers, which comprises ~1% of the substance and metabolizes to alkoxyacid. New studies confirmed the minor β-isomer developmental toxicity and showed, for the first time, testicular toxicity. (INSERM 2006).

18 The oral, rat LD50 value for one constituent of Lanadol Avant, Alcohols C13-C15 branched and linear, ethoxylated (CAS #106232-83-1) [present at up to 35% of the individual

detergent formulation], is >2,000 mg/kg. This value pertains to the individual chemical and may not be relevant with regard to the mixture. 19

See note 19 - 2-(2-butoxyethoxy) ethanol (CAS# 112-34-5) includes the central nervous system as a target organ. 20

At high concentrations (>6% in air), CO2 causes CNS effects, at sufficient concentrations causes asphyxiation. 21

See note 19 - 2-(2-butoxyethoxy) ethanol (CAS# 112-34-5) includes kidneys, liver, the heart and blood as target organs. 22

ACGIH TWA-TLV (ACGIH 2006) 23

OSHA PEL (NIOSH 2004) 24

ACGIH TWA-TLV for Stoddard Solvent; No values established for specific hydrocarbons in these products. (ACGIH 2006) 25

Manufacturer’s recommended limit (DCC 2011) 26

ACGIH TWA-TLV (ACGIH 2006)

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APPENDIX B 5.0 REGULATORY AND SAFETY COMPARISON OF ALTERNATIVES

Many of the alternatives to perc have safety considerations, in particular, flammability. These characteristics

often require a regulatory framework to ensure safe operation. These requirements may be a significant factor

for small dry cleaning businesses. The Massachusetts Board of Fire Prevention Regulations (527 CMR 3) adopts

NFPA 32 (National Fire Protection Association code for dry cleaning plants) by reference. In addition, dry

cleaners using combustible solvents should check with their local fire department to determine applicability of

Massachusetts process safety management regulations 527 CMR 33 (MADFS).

TABLE 7: DRY CLEANING ALTERNATIVES – REGULATORY AND SAFETY INFORMATION

Regulatory Considerations

Perc Wet Cleaning Carbon Dioxide

High Flash Point Hydrocarbons

Acetal Propylene


nPropyl Bromide

Regulatory Information

Regulated as hazardous air pollutant (HAP) under the Clean Air Act

Yes - HAP No No No No No No No

Regulated as VOC under the Clean Air Act (CAA) NAAQS

No, exempt under CAA

No No Yes Yes Yes No, exempt under CAA

Yes

Solid waste regulated as hazardous

(US RCRA or MassDEP)

Yes - Listed hazardous

waste No No

Waste oil must be managed as a hazardous waste

in MA

No No No No

Flammability classification

(solvent class) (NFPA 32)

None None None Combustible

liquid (Class IIIA solvent)

Combustible liquid (Class IIIA solvent)

Combustible liquid (Class IIIA or IIIB solvent)

Combustible liquid (Class IIIA solvent)

NA29

Chemical reportable under US EPA Toxics Release Inventory

Yes No No No No No No No

Chemical reportable under Massachusetts Toxics Use Reduction Act

Yes, higher hazard

substance No No No No No No Yes

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NA = not applicable

27

Note: there are inherent difficulties with determining flash point of halogenated hydrocarbon liquids. Some test methods show no flash point for nPB; others show a flash point

of 72°F (ECBI 2002). In MA nPB is considered non-flammable; in the European Union it is classified as R11 (highly flammable) (EU 2009).

Regulatory Considerations

Perc Wet Cleaning Carbon Dioxide

High Flash Point Hydrocarbons

Acetal Propylene


nPropyl Bromide

Regulatory Information (continued)

System regulated under Massachusetts Environmental Results Program

Yes No No No No No No No

Other regulatory considerations

Leak detection and repair required

Wastewater may require permit for

discharge to sewer. MA facilities on

septic must discharge to holding

tank or obtain groundwater

discharge permit.

High pressure storage may

require compliance with codes

Compliance with local fire safety codes required

Compliance with local fire safety

codes required

Compliance with local fire safety codes

required

Compliance with local fire safety codes

may be required

None

Physical Safety Information

Flash point (°F) NA27

NA NA 160 - 212 142 NA or

7229

171 NA

Other safety concerns

Combustion byproducts include HCl

and phosgene

None

Safety hazard associated with high pressure

equipment

None None None Combustion byproducts include HBr

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The following highlights are indicated from the safety and regulatory data presented in Table 7:

Wet cleaning wastewater discharges to sewer/publicly owned treatment works may require a municipal discharge

permit agreement; cleaners must contact their municipal operator to determine what restrictions may apply.

Common restrictions include limits on the amount of oils and grease or suspended solids, as well as pH limitations

on wastewater discharges. Wet cleaning wastewater may not be discharged to septic systems without first

obtaining a groundwater discharge permit in Massachusetts – a costly and time-intensive process. Utilizing an

industrial wastewater holding tank that complies with the applicable regulations, prior to transporting wastewater

to a publicly owned treatment works, is also an option for cleaners on septic systems. No other regulatory or

safety considerations apply to wet cleaning systems.

Cleaners should be aware of the hazard and regulatory requirements of spotting chemicals, regardless of which alternative system they are using.

Compliance with local fire safety codes is likely required with siloxane, propylene glycol ether systems, and acetals,

which are volatile and combustible. No other regulatory compliance requirements have been identified. Because

the acetal solvent is a new technology for dry cleaning it is unclear whether regulatory restrictions may be

developed as more information becomes available.

The high pressure CO2 vessels may be subject to local building code restrictions for high pressure equipment.

Physical safety concerns are associated with risk of explosion and the ability of high concentrations of released CO2

to asphyxiate workers in the event of a leak.

Compliance with local fire safety codes is required for all operations using hydrocarbons. In addition, the solid

waste associated with a hydrocarbon system is considered waste oil which, in Massachusetts, must be managed as

hazardous. HC systems have inherent safety concerns associated with the combustibility of the primary solvent.

nPB is now reportable to MassDEP under TURA as a listed toxic chemical. Because it is a VOC, there are air

regulations that apply to nPB systems.


APPENDIX B 6.0 RESOURCES ON ALTERNATIVES

The information above was gathered from a variety of sources including academic research and vendor data. There are many other sources of information available that could help you in reaching a decision about when to switch to an alternative and which one is best for you and your facility.

For questions about regulatory compliance, TURA and ERP form filing see:

The Department of Environmental Protection (MassDEP), through its Bureau of Waste Prevention, is responsible for implementing TURA. MassDEP certifies TUR Planners, receives and reviews toxics use reports submitted by companies subject to TURA requirements, provides guidance to both, takes enforcement actions against non-reporters, manages collected data and makes it available to the public, and evaluates the state's overall progress as it works toward the goals of TURA. http://www.mass.gov/eea/agencies/massdep/toxics/tur/

For a confidential site visit to discuss regulatory compliance or potential alternatives see:

The Office of Technical Assistance and Technology (OTA) is a non-regulatory agency within the Executive Office of Energy and Environmental Affairs that provides free, confidential, on-site technical and compliance consultations to manufacturers, businesses and institutions. OTA also facilitates the development of innovative TUR technologies and sponsors workshops and conferences that focus on toxics use reduction activities for specific industry sectors. http://www.mass.gov/eea/grants-and-tech-assistance/guidance-technical-assistance/agencies-and-divisions/ota/

For a full report on alternatives completed in 2012 and information about converting to professional wet

cleaning see:

The Toxics Use Reduction Institute (TURI), on the Lowell campus of the University of Massachusetts, provides TUR education and training for professionals and the general public, conducts a technology transfer program and sponsors research into the development of cleaner, safer production materials and technologies. The Institute consults with an eleven-member Science Advisory Board on issues such as the addition or deletion of chemicals from the TURA chemical list and the designation of chemicals as higher or lower hazard. www.turi.org and www.turi.org/drycleaning

Additional technical and training assistance can be available through:

Your detergent or equipment vendor – keeping in mind you should shop around to weigh various opinions and costs

Trade associations in the New England area: o Northeast Fabricare Association

Contact: Peter Blake ([email protected]); (800) 442-6848 o Korean Dry Cleaners Association

Contact: Harry Cho ([email protected]); (978) 535-6936 or Myeong Lowe ([email protected]); (617) 767-5693

o MA Wet Cleaning Workgroup, contact Joy Onasch at TURI ([email protected]); (978) 934-4343

http://www.mass.gov/eea/agencies/massdep/toxics/tur/

http://www.mass.gov/eea/grants-and-tech-assistance/guidance-technical-assistance/agencies-and-divisions/ota/

http://www.mass.gov/eea/grants-and-tech-assistance/guidance-technical-assistance/agencies-and-divisions/ota/

http://www.turi.org/







Financial assistance to convert to one of the alternatives may also be available through:

Your local bank, given a good credit rating

The Small Business Administration, Boston Regional Office: http://www.sba.gov/about-offices-content/2/3162 or (617) 565-5590

Accion USA, if access to traditional capital is not possible: http://www.accionusa.org/home/small-business-loans.aspx

TURI, for full conversion from either perc or nPB to dedicated wet cleaning. Visit www.turi.org/drycleaning for an application, up to $15,000 may be available as a grant.

http://www.sba.gov/about-offices-content/2/3162

http://www.sba.gov/about-offices-content/2/3162

http://www.accionusa.org/home/small-business-loans.aspx

http://www.accionusa.org/home/small-business-loans.aspx



APPENDIX C: COMPARATIVE ANALYSIS

This Appendix contains a comparative analysis worksheet to assist you in considering alternatives to

perchloroethylene. Various aspects such as cost, performance, capital and operating costs must be weighed to

make a fully-informed decision. We have drawn on various sources to produce a worksheet that provides

information needed for a full comparative analysis. The Comparative Analysis worksheet includes a column on

the left for you to include the data from your current facility and one on the far right for you to record your

comments and information specific to your needs and concerns for each data row. There are also summary

rows at the bottom to record your conclusions about advantages or disadvantages, and remaining questions you

may wish to pursue before making a decision. We have included symbols denoting "equal," "approximately

equal to," "more than or less than," "greater than" and "less than," as quick summaries of what the information

suggests. These are not strict mathematical quantities but represent the best estimate of how the burden or

value of the alternative compares to that of perchloroethylene use.

Following the Comparative Analysis Worksheet we have also provided a summary of the information drawn

from eight case studies of cleaners in Massachusetts using various alternatives to perc. We suggest that as you

go through the Comparative Analysis Worksheet that you also consult the Case Study Summary, as it provides a

slightly different way of weighing the various aspects, and is drawn from near-by real world examples. However,

you should make careful note of the size of each of the case study facilities as they may vary greatly from your

facility, and the numbers presented should be scaled accordingly as you make your comparisons. The Case

Study Summary also includes columns for recording specific information about your shop, so that you can

capture details that may be more or less important in your case, and tailor the exercise of comparing

alternatives to your individual concerns and goals.

Finally, we have included a recent data set compiled by the Drycleaning & Laundry Institute from a panel

discussion at the Clean ’13 event held in New Orleans in June of 2013. The data is direct from the industry

representatives on hand for each of the solvents compared. Note, however, that professional wet cleaning is

not included in this data set. The data does include points about cycle length, wash time, costs, etc. This may be

another helpful resource in comparing alternatives you are considering.


COMPARATIVE ANALYSIS WORKSHEET OF ECONOMICS, PERFORMANCE, ENVIRONMENTAL AND HEALTH CHARACTERISTICS OF ALTERNATIVE DRY CLEANING SOLVENTS

(July 31, 2013)

Based on case studies and research conducted by the Toxics Use Reduction Institute, to be updated in response to comments and as new information becomes available.

Note: All costs are approximate and have not been verified with vendors

FACTOR THAT MAY VARY WITH TYPE OF EQUIPMENT

Your perc data

Perc (Capital Costs for new machines are provided; fill in your operating costs for your existing perc machine)

Wet Cleaning High Flash Point

Hydrocarbon (e.g., DF2000)

Acetal (Solvon K4) Propylene Glycol Ethers (Solvair,

Rynex)

Siloxane (Green Earth)

nPB (DrySolv) Your

comparison

>, >> or >>> means greater than -- the more arrows the greater the difference <, <<, or <<< means less than -- the more arrows the greater the difference

= means equal to ≥ means greater than or equal to ≤ means less than or equal to

± means plus or minus ≈ means approximately equal to

COST CONSIDERATIONS

Capital Costs

Washing / Drying / Finishing Equipment (cost range depends on size and extra features; based on 2005 data)

$40,000 to $65,000 10% < perc ± 10% perc 25% - 50% > perc ≥ perc 20 -25% < perc ≈ perc

$36,000 to $61,000 $38,000 to $75,000

$50,000 to $100,000 $56,000 to $90,000 $30,500 to $55,000 $40,000 to $60,000

(If No Public Sewer) Holding Tank or Wastewater Treatment System with Groundwater Discharge Permit

No cost » perc, if no public

sewer = perc = perc = perc = perc = perc

illegal to discharge cleaning wastewater to septic system

no wastewater discharge

no wastewater discharge no wastewater discharge no wastewater discharge

no wastewater discharge

Fire Code Compliance (if Class II or III solvent)

No cost: not a flammable liquid

= perc >> perc >> perc >> perc >> perc = perc

not combustible Class III solvent* Class III solvent* Class III solvent* Class III solvent* not combustible

*Retrofit building to meet NFPA 32 code for Type III solvents (flame barriers, automatic sprinklers unless <330 gallons on site, and have specified fire protections in equipment). Local codes may apply as well.



Your perc data





Rynex)


nPB (DrySolv) Your

comparison




Operating Costs

Equipment Maintenance Costs

Gaskets and Seals Replacement

Requirement to test weekly and fix identified leak within 24 hours

<< perc < perc < perc < perc < perc > perc

Water does not break down gaskets and seals

Causes need for frequent replacement of gaskets and seals; however there is not requirement for testing and replacement

Labor Costs

Initial Staff Training

Requires training on computer controlled equipment and tensioning machines

Training necessary for all new equipment





Finishing and Pressing

< perc = perc ≤ perc ≤ perc = perc = perc

tensioning equipment needed (minimizes need to press clothes)

manufacturer says less wrinkling during cleaning cycle

manufacturer says less wrinkling during cleaning cycle

Pre Spotting < perc = perc < perc ≈ perc > perc < perc

Regulatory Compliance: Air Pollution

Weekly leak detection & repair, equipment monitoring, recordkeeping per ERP Workbook because perc is a hazardous air pollutant. ALL co-residential and ALL co-located perc machines must cease operation on or by December 21, 2020.

< perc none: unless

use >2000 pounds per year

none: unless use >2000 pounds per year

none: unless use >2000 pounds per year

none: unless use >2000 pounds per

year

none: unless use >2000 pounds per

year

no air pollutants if > 2000 lb, Air VOC emissions permit required, would involve recordkeeping and controls

if > 2000 lb, Air VOC emissions permit required, would involve recordkeeping and controls






Your perc data





Rynex)


nPB (DrySolv) Your

comparison




Regulatory Compliance: Hazardous Waste

Maintaining proper labeling, storage conditions, record keeping, shipping and disposal per ERP Workbook

<< perc = perc < perc < perc < perc < perc

no hazardous or industrial waste

maintaining proper labeling, storage conditions, recordkeeping, shipping and disposal

no hazardous waste no hazardous waste no hazardous waste no hazardous waste

Materials and Resource Costs

Water Use (Cleaning and Condensing / Chilling) and Sewer Discharge (if applicable)

Water used for condenser/chiller

≈ perc

no chilling/condensing, but

water used for cleaning

= perc = perc = perc = perc = perc

Alternatives compared to refrigerated condenser/chillers

Cleaning Chemicals -- Detergent

> perc = perc = perc = perc = perc = perc

Solvent no cost = perc > perc > perc > perc >> perc

Energy (electricity for machine operation including solvent recovery)

<< perc

<< perc if no

distillation = perc if

distillation

<< perc < other solvents

= perc > perc if distillation

< perc if no distillation

= perc

no distillation / solvent recovery

For distillation about 1/2 of other solvents

high temperature required for distillation

Natural Gas / Oil (heating, pressing, steam, cooling)

< perc = perc = perc = perc = perc = perc

less pressing



Your perc data





Rynex)


nPB (DrySolv) Your

comparison




Fees

Technology Licensing no cost = perc = perc = perc = perc

$2500/year for the first, $1250/year for

additional machines

= perc

Regulatory Compliance Fees

$250 annual ERP Compliance Fee + TURA fees for large users

<< perc << perc << perc << perc << perc << perc

TURA fee for very large users

Unquantifiable Costs

Customer Acceptance / Good Will

>> perc > perc > perc > perc > perc = perc

No loss of customers advertised as "green"

advertised as "green" advertised as "green"

advertised as "green”

Potential Liability from Spill or Accidental Release

Risk: highly toxic solvent that persists in air, and sediments, and groundwater

<<< perc < perc << perc << perc < perc = perc

Risk of Fire

Minimal risk, not a flammable liquid

= perc >> perc >> perc >> perc >> perc = perc

not a flammable liquid Class III combustible solvent

Class III combustible solvent Class III combustible solvent

Class III combustible solvent

not a combustible liquid

Worker Health and Safety (See also Human Health Risk section below)

Risk: volatile toxic solvent; IARC carcinogen, and other adverse respiratory, neurological, and skin effects

<<< perc < perc < perc < perc < perc = perc

no toxic solvents in washing – pre-spotting chemicals should be checked

pre-spotting chemicals should be checked




Volatile toxic solvent; National Toxicology Program has identified it as a likely carcinogen, with other adverse respiratory, neurological, and skin effects. pre-spotting chemicals should be checked



Your perc data





Rynex)


nPB (DrySolv) Your

comparison




TECHNICAL CONSIDERATIONS

Cycle Time << perc >> perc >> perc > perc >> perc = perc

20 - 40 minutes: washing and drying in separate machines so cycles can overlap

60-75 minutes 60-65 minutes > 45 minutes 53-58 minutes 45 minutes

Materials does not handle well

Leather, suede, beads, delicates

Leather, suede and fur Vinyl appliqués Appliqués or decorations

glued to fabric None identified None identified

Leather, suedes, beads, delicates

Aggressive-ness of solvent (roughness on clothes)

aggressive < perc < perc < perc unclassified < perc = perc

ENVIRONMENTAL & HEALTH CONSIDERATIONS

Environmental Risks

Persistence in soil, sediment, and air is an issue, as well as some aquatic toxicity. Hazardous Air Pollutant

<<< perc < perc << perc << perc < perc = perc

no toxic solvents in washing – pre-spotters should be checked

serious issues with aquatic toxicity, moderate issues in other areas. Volatile Organic Carbon that contributes to smog

based on current information, appears to be low to moderate issues. Volatile Organic Carbon that contributes to smog

based on current information, appears to be low to moderate issues. Volatile Organic Carbon that contributes to smog

high issues with sediment and air as well as aquatic toxicity

persistence in air, high aquatic toxicity,and a Volatile Organic Compound that contributes to smog



Your perc data





Rynex)


nPB (DrySolv) Your

comparison




Human Health Risks

IARC has identified this as a probable carcinogen and skin, eye and respiratory irritant; it is toxic to the liver,kidney, nervous, immune and hematological systems. Recommended occupational exposure limit 25 ppm

<<< perc < perc unknown < < perc < perc = perc

skin and eye irritant from detergent concentrate

Skin, eye, respiratory irritant, and toxic to lungs, kidneys and nervous system. Recommended occupational exposure limit: 5000 ppm

possible skin and eye irritant; no occupational exposure limit established

skin, eye, and respiratory irritant, toxic to the nervous system, liver and kidneys; no occupational exposure limit established

Skin and eye irritant, toxic to liver and immune system, some evidence of carcinogenicity and toxicity to the reproductive/ developmental and nervous systems. Recommended occupational exposure limit: 10 ppm

Potent neurotoxin; National Toxicology Program has identified it as reasonably anticipated to be a human carcinogen; eye, skin, and respiratory irritant, toxic to liver and kidney and to the digestive, blood and nervous systems. Recommended occupational exposure limit: 10 ppm

WOULD YOU CONSIDER THIS OPTION?

Advantages

Disadvantages



Your perc data





Rynex)


nPB (DrySolv) Your

comparison




Questions to ask Vendor, TURI, OTA, Trade Organization, Other Dry Cleaners, etc.


CASE STUDY SUMMARY FOR DIFFERENT TYPES OF DRY CLEANING FACILITIES

July 31, 2013 (page 1 of 2)

(to be updated as additional information becomes available)

Cost Element Perc Perc Wet Cleaning Hydrocarbon Acetal PGE Siloxane nPB How does your

shop compare? Your Shop Case Study Facilities

Shop Sizing:

Pieces/day (DC)

60 100 TBD 650 ~300 100 100

Pieces/day (Laundry) 50 500 600 350 100 30

lbs/day (DC) - - - 260 - -

lbs/day (Laundry) - - - - - -

FTEs 7 2.5 15+ 4.5 4+ 2.5

Square footage 1300 1,500 3600 4000 2800 1700

Capital Costs: Dry Cleaning $44,000 $46,900 $90,000 $90,000 $49,620 $40,000

Other Investments $0 $0 $ 0 as needed $115,285 $0

Time Investments:

Load size (pounds) 30 30 50 60-70 40 40

Cycle time (mins/load) 40

12-25 washer; 8-15 dryer 65 120 60 35

ERP/DEP paperwork

(average hours/year) 2 0

2 (for waste pick-ups) 10 5 hrs/week 0

Spotting time (average

hours/day) 0.3 6 4 0.5 1.5

Finishing time (average

hours/day) 5 6 pressers at 8

hrs/day 6 4 5

Training on new methods (hours/emplo

yee) 0

6 initial hours for tensioning equip; 3 initial hours for

washer 4 hrs for spotter 0 ? 1-2 days

OTHER

Also paid $3600 for start-up

solvent distiller in use

Performance (items or $/month)

Send-outs 0 0 0 13 0 0

Redos 0 0 0 27 1 3

Claims $65 0 0 2 0 0


CASE STUDY SUMMARY FOR DIFFERENT TYPES OF DRY CLEANING FACILITIES

July 31, 2013 (page 2 of 2)

Cost Element Perc Perc Wet Cleaning Hydrocarbon Acetal PGE Siloxane nPB How does your

shop compare? Your Shop Case Study Facilities

Operation Costs ($/month)

Machine Maintenance $0 $32 $0 $1,200 $206 $42

Filters $34 0 $0 $100 $26 $0

Solvent $130 0 $36 $200 $520 $225

Detergent $74 $180 $326 $0 $24 $10 Spotting

agents $18 $3 $200 $500 $8 $60

Waste disposal $125 0 $92 $54 $49 $21

Regulatory/ permitting $11 0 $0 $54 $8 $0

Licensing fees $0 0 $0 $0 $183 $0

Resource Use (Unit/month)

Electricity (kwH) 3027 1606 8284 625 2610 1962

Electricity ($) $513 $234 $1,707 $120 $521 $367 Natural Gas

(therms) 98 0 1435 0 377 480

Natural Gas ($) $90 0 $1410 0 $378 $615

Oil (gallons) 0 424 0 675 0 0

Oil ($) 0 $1,086 $0 $2,360 $0 $ 0 Water

(100cuft) 24 26 60 - 34 24

Water ($) $66 $142 $275 $230 $160 $ 107 Sewer (100

cuft) 24 26 60 - 34 24

Sewer ($) $77 $186 $836 $310 $254 $136 Monthly total Operating Cost (w/out labor)

$1,203 $1,863

$4,882 $5,128 $2,237 $1,583

Monthly per piece total operating cost (w/out labor)

(110/day or ~2640/month)

$0.46

(600/day or ~14,400/month)

$0.13

(1250/day or ~ 30,000/month)

$0.16

(650/day or ~ 15,600/month)

$0.33

(200/day or ~ 4800/month)

$0.47

(130/day or ~ 3120/month)

$0.50


DRYCLEANING & LAUNDRY INSTITUTE CLEAN SHOW ’13 PANEL DISCUSSION DATA COMPILATION COMPARING THE SOLVENTS

Source: http://www.natclo.com/1308/solvents.htm

Solvent/ Manufacturer

Perc

Dow

Hydrocarbon

R.R. Street & Co

Solvon K4

Kreussler

Rynex

Adco

GenX

Caled

GreenEarth

GreenEarth Cleaning

Cycle length (minutes) 45 2 baths: 55-65

1 bath: 50-60

2 baths: 70

1 bath: 62

74 55-60 60

Wash time (minutes) 15-20 18-20 15-20 75 4-8 17

Drying time (minutes) 30-35 28 48 with cool down 60 25-30 35

Specific machine required? Class IV Class IIIA Class IIIA with vacuum still K Series Class IIIA Class IIIA Class IIIA

Fees/Licenses No No No No No $2,500/year

Proprietary products required?

No No products Yes, Kreussler Booster sizing No Many approved available, top brands

Average cost per gallon $25 $13.95 $30.70 $36 $29.41 $21-$34

Average solvent mileage (pounds cleaned per gallon)

750 to 1,000 1,500 to 1,800

4,000 in K series

4,500

Minimum of .5% of load

3,000+ 800 to 1,100 1,500

Recommended waste disposal

Licensed waste hauler Appropriate waste hauler Licensed waste hauler Regular waste hauler Non-hazardous municipal waste

Licensed waste hauler

Number of machines in U.S. 36,000 U.S. 10,000+ 200 U.S.

400 global

10 U.S.

13 global

800 U.S.

1,000 global

More than 900 U.S.

1,700 global

Any major issues? Proper handling and disposal; restrictions on location; special reporting & permitting

None None Residual solvent temperature after drying

None None

Rumors or misconceptions? 1. Banned

2. Unavailable

3. Stabilizer disappears when distilled

1. Doesn’t clean 1. Odor of solvent will be a problem

None 1. Doesn’t need detergent 1. Doesn’t clean

2. Banned in Canada

Top 3 benefits 1. Safety

2. Proven performance

3. Economical

1. Cost effective

2. Virtually odorless

3. Ease of transition and ongoing operations

1. Exceptional cleaning performance

2. Unmatched solvent mileage

3. Environmental & occupational safety for clients, staff, landlords, and drycleaners

1. Better soil removal

2. Fewer reruns

3. Great solvent mileage

1. Better performance for oil & water stain removal

2. Cheaper spotting labor and chemical cost

3. Faster cleaning with no harsh smell

1. Favorable regulatory profile

2. Garment makers’ recommendations

3. Landlord specified locations

http://www.natclo.com/1308/solvents.htm


APPENDIX D: POLLUTION PREVENTION, HEALTH & SAFETY BEST MANAGEMENT

PRACTICES

General Record-keeping checklist:


Good Management Practices: Emergency Preparedness Checklist


APPENDIX E: SPOT REMOVERS

The following information is supplied from the Safer Spotting Chemicals Best Practices for Textile

Cleaning -- May 2007; EPA & Department of Toxic Substances Control.

Many cleaners have converted away from PERC dry cleaning to safer alternative processes. A number of them, however, continue to use TCE and PERC spotting agents. Use of these spotting agents will make the waste streams generated by the non-PERC garment cleaning processes hazardous. How do I know if my spotting agent contains TCE or PERC? Ask your spotting chemical supplier for a Material Safety Data Sheet (MSDS) for the spotting agent. If the spotting agent contains TCE or PERC, it should list the chemical under the second section of the MSDS sometimes labeled "Composition / Information on Ingredients" or "Components." The Chemical Abstract Service (CAS) number should also be listed. This is important because suppliers may call TCE and PERC by different names, but the CAS number stays the same. The CAS number for TCE is 79-01-6 and for PERC 127-18-4. Have safer alternative spotting agents been tested? The Institute for Research and Technical Assistance (IRTA) is a technical nonprofit organization. During a project sponsored by California Environmental Protection Agency’s Department of Toxic Substances Control (DTSC) and U.S. EPA Region IX, IRTA tested low-VOC safer alternatives with a number of textile cleaning facilities using a range of different textile cleaning processes. IRTA and the test facilities found that the alternative POG spotting agents worked effectively. Are the safer alternative POG spotting agents available? There are some alternative spotting agents on the market. Many of these contain other ingredients that are toxic or are Volatile Organic Compounds (VOCs) that contribute to smog. The best alternatives from an overall health and environmental standpoint are water-based and soy based products.


APPENDIX F: MASSDEP INSPECTOR CHECKLIST

Environmental Results Program- DRY CLEANERS SECTOR

Inspection Checklist --- August 2014

Instructions:

The inspection checklist includes Dry Cleaners Certification workbook references and

citations to 310 CMR 7.26(10)-(16) that will help to determine compliance. Workbook

references and regulatory citations are inside square brackets (e.g., [A-1] and [310

CMR 7.26(14) (d)]). The Inspection Checklist also provides “cues” (text in ITALICS) to

assist inspectors in understanding when to seek verbal responses from the facility

owner or manager, make visual observations, or a combination of the two. The “cues”

are mainly provided for AQ requirements.

The evaluation of E.R.P. for dry cleaners following inspections helps to determine whether or not the workbook-plus-self-certification process has improved the compliance rate, improved environmental behaviors in this sector, and will identify owners who falsely certified compliance, documenting any enforcement actions.

Inspectors may investigate beyond the workbook requirements, as necessary, if

indications of significant environmental threat or damage exist.

Some of these questions will require use of inspectors’ best judgment. Please try to

obtain the most accurate assessment possible. Circle or fill-in your response to each

question or requirement.

DO NOT LEAVE ANY QUESTIONS BLANK UNLESS YOU HAVE BEEN DIRECTED

TO SKIP A QUESTION. If absolutely necessary, indicate “Could not determine” next to

a question and include the reason why. A completed inspection checklist must be

returned to Boston for each facility inspected. They will be used to make statistical

extrapolations about the effectiveness of E.R.P. on this industry sector.

BWP needs to assess the state of compliance and environmental behavior in each

sector. Any questions or comments, please contact Paul Reilly at 617 556-1097.


1 Does this facility perform perchloroethylene-based dry cleaning on site? Y N

If YES, SKIP to Question 2

IF NO, ANSWER 1a-c below and STOP

1a Is this facility closed? Y N

1b Is this facility a storefront only? Y N

1c Does this facility use only non perchloroethylene based dry cleaning machines? Y N

2 Are there any other occupants in the building that houses this dry cleaner?

(A strip mall or mall counts as the same “building”)

IF NO, SKIP to Question 3

Y N

IF YES, PROCEED TO QUESTION 2a

2a Are there any residential units in the building? Y N

2b Are there any licensed day care centers in the building? Y N

2c Are there any schools in the building? Y N

2d Are there any health care facilities in the building? Y N

2e Are there any children’s pre-schools in the building? Y N

2f Are there any youth or senior centers in the building? Y N

2g Are there any prisons in the building? Y N

2h Is the unit leased? Y N

2i Is the unit owner occupied? Y N


AIR QUALITY

3 Are previous month’s perchloroethylene purchases recorded on the first day of each

month? [C -16]

(Check log or records enter Y as long as they have the records even if no log)

Y N

4 Is the total perchloroethylene purchased in past year calculated on

the first day of each month? [C -16] [310 CMR 7.26(15)(d)2.]

(Check log)

Y N

5 Are dry cleaning system specification and operating manuals kept onsite? [C -14]

[310 CMR 7.26(13)(k)

(Ask to see manuals)

Y N

6 Are all emission control device specification and operating manuals kept onsite? [C-

14] [310 CMR 7.26(13)(k)]

(Ask to see manuals; describe any “extra” systems and operating procedures)

Y N

7 Is leak detection performed weekly, following the workbook protocol and using proper

leak detection equipment? [C-12] [310 CMR 7.26(13)hi)ij); (15)(d)3.]

(Ask to see leak detector and demonstration of leak detection procedures for each

machine (while operating).)

Y N

8 Is a log of weekly leak checks kept onsite? (Ask to see log) Y N

9 Is the operation of the refrigerated condenser monitored weekly, using ONE of the

following options (10 or 11)?

Y N

10 Is the temperature at the end of cycle measured on the outlet side of the refrigerated

condenser and recorded weekly? [C-9, C10] [310 CMR 7.26(14)(a)1.; (15)(d)5.]

Y N

11 Are the refrigeration system high and low pressure gauges monitored during the

drying cycle, to verify that they are within the ranges specified in the manufacturer’s

operating instructions?

Y N


12 Is a log of weekly emission control monitoring kept onsite? (Ask to see log) Y N

13 Are all problems repaired within 24 hours or, if not possible, are parts ordered within 2

days and installed within 5 days of receipt?[C-11, C-13] [310 CMR 7.26(13)(j)]

Y N

14 Is a log of all problems, repairs, and parts ordered kept onsite?[C-14] [310 CMR

7.26(15)(d)3.,4.]

(Ask to see log)

Y N

15 Are dry cleaning systems operated according to manufacturers recommendations?

[310 CMR 7.26(13)(b)]

(Ask to be walked through facility and shown operating procedures and compare to

manual. Have facility give a couple of examples.)

Y N

16 Is virgin perchloroethylene stored in closed, non-leaking tanks or containers? [C-33]

[310 CMR 7.26(13)(g)]

(Examine tanks/containers)

Y N

17 Are all machine doors closed immediately after transferring articles and kept closed at

all times except during maintenance? [310 CMR 7.26(13)(a)]

(Observe operations and ask verbally)

Y N

18 Is perchloroethylene odor absent in the facility (while the machine is operating)? Y N

19 Are seals and gaskets periodically replaced before they become brittle?

(Verbal) (P 2 -- Not a regulatory requirement)

Y N

20 Are spent filter cartridges drained in housings/sealed containers for 24 hours prior to

disposal? [310 CMR 7.26(13)(f)]

(Observe operations and ask verbally)

Y N

21 Does the facility have any Transfer Machines?

IF YES, CEASE operation. Transfer Machines are prohibited.

Y N

22 List the installation date of each dry-to-dry machine


23 Does this facility have any dry-to-dry machines installed before 12/9/91?


Y N

23a Do all dry-to-dry machines installed before 12/9/91 have a carbon adsorber that

was installed prior to 9/22/93 or a refrigerated condenser? [C-7] [310 CMR 7 .26

(12)(a)1.]

(Look for refrigerated condenser. If no condenser, look for carbon adsorber and ask

to see installation records, receipts, look at model numbers, or get a specific verbal

date for each machine )

Y N

24 Do all dry-to-dry machines installed after 12/9/91 have a refrigerated condenser? [310

CMR 7.26(12)(a)2]

(Ask look for refrigerated condenser)

Y N

25 Were any dry-to-dry machines installed after 12/21/05?


Y N

25a Do the dry-to-dry machines installed after 12/21/05 have a secondary carbon

adsorber, as well as a refrigerated condenser?

Y N

26 Is the cleaning cycle stopped only after the refrigerated condenser temperature

reaches less than 45 F? [310 CMR 7.26(13)(c)4.;(14)(a)1.; (15)(d)5.]

(Ask procedures and look for any automatic feature to prevent door from being

opened until temperature drops below 45 F; check log)

Y N

27

If the Facility has a boiler of at least 1 MMBTU/HR capacity, is it operated in

compliance with the standards in [310 CMR 7.02, 7.04, 7.05, or 7.26(30) – (37)]?

Y

N

HAZARDOUS WASTE REQUIREMENTS

28 Does the facility have a Hazardous Waste generator ID? [C-25] Y N


29 Circle the facility’s hazardous waste status: VSQG SQG LQG [C-26]

[310 CMR 30.353(5)] [310 CMR 30.061(1)]

Y N

IF THE FACILITY IS A VSQG, SKIP to Question 31

30a Does the facility have an employee notification system? [SQG: 30.351(9)(c)1. LQG:

30.340(1)(d)2 & 30.524(2)(a)] CHECK THIS

Y N

30b Does the facility have a device to summon emergency response agencies? [SQG:

30.351(9)(c)2.] LQG: 30.524(2)(b)]

Y N

30c Does the facility have a portable fire extinguisher and spill control equipment? [SQG:

30.351(9)(c)3 LQG: 30.524(2)(c)]

Y N

30d Does the facility have adequate fire suppression equipment? [SQG: 30.351(9)(c)

LQG: 30.524(2)(d)]

Y N

30e Does the facility have a program to test emergency equipment? [SQG: 30.351(9)(d)

LQG: 30.524(3)]

Y N

30f Does the facility have an adequate aisle space and clearly marked exits? [SQG:

30.351(9)(c)5 LQG: 30.524(5) & 30.524(2)(e)]

Y N

30g Does the facility have a program to familiarize and obtain agreements from local ER

agencies? [SQG: 30.351(9)(j) LQG: 30.521(5)]

Y N

30h Does the facility have a designated emergency coordinator? [SQG: 30.351(9)(b)

LQG: 30.521(7)]

Y N

30i Has the facility posted names and telephone numbers of emergency coordinators,

locations of fire alarms and extinguishers, fire department telephone numbers, and

evacuation routes? [SQG: 30.351(9)(c)6. LQG: 30.524(2)(f)]

Y N

30j Does the facility have a log of weekly storage area inspections? [SQG: 30.351(8)(a)

30.340(1)(a)1.d. 30.686 30.340(1)(a)1.d.]LQG

Y N

31 Does the facility have emergency notification procedures and training? [C-37, 38] Y N

32 Is the facility in compliance with quantity and time limits for HW storage? [C-28, C-29]

[VSQG-310 CMR 353(3)(4)] [SQG-310 CMR 30.351(6)(7)] [LQG-310 CMR

30.340(2)]

Y N

33 Are containers labeled properly? [C-34, C-39] VSQG[30.353(6)(g) 30.682] SQG

[30.351(8)(a) ] LQG: [30.340(1)(b)]

Y N


34 Are containers in good condition and kept closed? [C-33] VSQG[30.353(6)(g)

30.683 30.340(1)(a)1.a. (LQG) 30.351(8)(a)]SQG

VSQG[30.353(6)(g) 30.685(1) 30.340(1)(a)1.c. (LQG) 30.351(8)(a)]SQG

Y N

35 Is there a separate, designated hazardous waste storage area, marked with line or

tape? [C-31] VSQG[30.353(6)(h) 30.340(1)(k) (LQG) 30.351(8)(b)]SQG

Y N

36 Are wastes appropriately segregated? [C-33] VSQG[30.353(6)(g) 30.688(2)

30.340(1)(a)1.e. (LQG) 30.351(8)(a)]SQG

Y N

37 Are hazardous waste containers stored on a crack-free surface that will contain leaks

or spills? [C-35] VSQG[30.353(6)(h) 30.340(1)(f) (LQG) 30.351(8)(b)]SQG

Y N

38 Is there adequate spill containment for outdoor storage area (110% of largest N/A

container or 10% of total storage, whichever is greater)? [C-35] VSQG[30.353(6)(h)

30.340(1)(g) (LQG) 30.351(8)(b)] SQG

Y

N

39 Is entrance by unauthorized people restricted? [C-31] VSQG[30.353(6)(h)

30.340(1)(i) (LQG) 30.351(8)(b)] SQG

Y N

40 Does the storage area have appropriate signage? [C-31] VSQG[30.353(6)(h)

30.340(1)(j) (LQG) 30.351(8)(b)] SQG

Y N

41 Are pallets used if containers are stacked? VSQG[30.353(6)(g) N/A

30.685(2) 30.340(1)(a)1.c. (LQG) 30.351(8)(a)] SQG

Y N

42 Is the storage area inspected weekly for leaks and is there adequate aisle space to

allow inspections?

vsqg 30.686 30.340(1)(a)1.d. (LQG) 30.351(8)(a)SQG] (weekly inspections)

vsqg 30.685(4) 30.340(1)(a)1.c. (LQG) 30.351(8)(a)]SQG (aisle space)

Y N

43 Has there been a perchloroethylene leak or spill of more than 10 pounds?

If NO, SKIP to Question 44

Y N

43a If IIf more than ten pounds of perchloroethylene was spilled or leaked, was DEP notified?

[C-36] 310 CMR 40.0311(1)(2)

VSQG[30.353(4)] SQG[30.351(9)(h)2.] LQG[30.340(1)(d)2.

30.524(6)(d)&(e)2.]

Y N


44 Is this facility a VSQG?


Y N

44a Does the facility self transport hazardous waste?

Y N

45 Does the facility use manifests and licensed transporters? [C-30] VSQG[30.353(12)

30.311(1) (LQG) 30.351(10)(e)] SQG

Y N

46 Are logs, shipping records, manifests kept for at least three years? [C-30]

VSQG[30.353(6)(e) 30.331(1) 30.351(10)(f)]SQG 30.340(1)]LQG

Y N

47 Are wastes shipped to a licensed TSDF or permitted HW recycler? [C-30]

VSQG[30.353(8)] [30.305(1) or (2) 30.340(1) (LQG) 30.351(10)(d)]SQG

Y N

INDUSTRIAL WASTEWATER REQUIREMENTS

48 Does this facility discharge industrial wastewater to a Publicly Owned Treatment

Works?


Y N

48a Are discharges to sewer free of perchloroethylene (other than separator water), and

contain no flammable materials, no corrosives, no solids, and no wastewater hotter

than 104 F? [C-19c] [310 CMR 72.04(3)(a)(b)]

Y N

48b Does the facility have a local sewer permit or other permission to discharge?

Y N

48b1 Is Is the facility in compliance with its local sewer permit?[C-7] [310 CMR 72.04(2)] Y N

49 Does this facility discharge to Surface Waters?


Y N

49a Is the facility in compliance with NPDES? [C-20a] [310 CMR 72.04(1)] Y N

50 Does this facility use a wet cleaning and/or laundering process at the facility? Y N


51 Does this facility discharge industrial (nonsanitary) wastewater to a septic system?

[C-21a]

Y N

52 Does this facility discharge industrial (nonsanitary) wastewater to ground?


Y N

52a Does the facility (or its lessor) have a Groundwater Discharge Permit? [C-22]

Y N

52b Is the facility in compliance with its state groundwater discharge permit? Y N

53 How does the facility dispose of its separator water? [C-17, C-23] [310 CMR

72.04(1)]

53a Discharge to sewer? Y N

53b Store in a container / tank and ship as hazardous waste? Y N

53c Use an evaporator ? Y N

53ci Is separator water treated (carbon adsorber) before evaporation? (This question is for

informational purposes only).

Y N

53cii Are filter changes recorded in a log book? (This question is for informational

purposes only).

Y N

54 Does the facility store industrial wastewater in containers? [C-24]


Y N

IF YES, PROCEED to Question 54a

54a Are records of wastewater analysis kept? [310 CMR 72.04(5)(c)] Y N

54b Are disposal manifests, bills of lading kept onsite for three years? [310 CMR

72.04(5)(c)]

Y N

54c Are containers in good condition? [310 CMR 72.04(5)(b)] Y N

54d Are containers stored on crack-free surface? [310 CMR 72.04(5)(b)] Y N

54e Are containers in good condition labeled "industrial wastewater" or "non hazardous

waste”)? [310 CMR 72.04(5)(b)]

Y N


54f Are any containers stored outdoors?


Y N

54f1 IF YIF YES, PROCEED to Question 51f1

Is there spill containment for outdoor containers? [310 CMR 72.04(5)(b)] Y N

55 Does the facility store industrial wastewater in tanks? [C-24]

IF NO, THE INSPECTION IS COMPLETE

Y N

IF YES, PROCEED to Question 55a

55a Are tanks labeled “Non hazardous” and securely stored on a crack-free, impervious

surface?

Y N

55b Does containment system equal 110% of capacity of total volume of all above ground

tanks?

Y N

55c Is there year round access for emptying? Y N

55d Is there odor control if needed? Y N

55e Is the tank lined with and made of compatible materials? Y N

55f Is the tank remotely or automatically filled?

IF NO, SKIP to Question 55g

Y N

IF YES, PROCEED to Question 55f1

55f1 Is there a bell and light alarm that sounds at 75% capacity? Y N

55g Is the tank manually filled?

IF NO, THE INSPECTION IS COMPLETE

Y N

55g1 D Do the manually filled tanks have visual or sight glass level measurement? Y N

INSPECTION IS COMPLETE

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